Draft interrogatories with 18questions that are to be sent to the Defendant, Jamie sanders

Picture below is just a sample.

expense, the reason for incurring each expense, and whether each expense has been paid. 6. Were you unable to work as a result of this occurrence? If so, state the dates during which you were unable to work, each employer during these dates, the type of work you were unable to do, and the amount of lost wages or income from each employer. 7. Have you recovered from the claimed injuries that resulted from this occurrence? If not, state the claimed injuries from which you have The plaintiff's current condition and medical history are important areas not recovered and any present disability. that should be explored thoroughly. 8. During the ten years preceding September 2, 2022, have you This can then be verified during the suffered any other personal injuries? If so, state when, where, and how plaintiff's deposition. you were injured and the name and address of each medical facility where, and physicians by whom, you were treated for these injuries. 9. During the ten years preceding September 2, 2022, have you been hospitalized, treated, examined, or tested at any hospital, clinic, physician's office, or other medical facility for any conditions other than those requested in Interrogatory No. 8? If so, state the name and address of each such medical facility and physician, the dates of such services, and the medical conditions involved. 10. State the full name and address of each person who witnessed, or claims to have witnessed, the collision between the vehicles Occurrence witnesses are obviously important in this kind of case. It's a involved in this occurrence. good practice to break them up by 11. State the full name and address of each person who has any category in appropriate cases. knowledge of the facts of the collision other than those persons already identified in Interrogatory No. 10. 12. Describe your vehicle that was involved in this occurrence, any damage to your vehicle as a result of this occurrence, the name and address of any firm repairing your vehicle, the amount billed for repairs, when such repairs took place, and whether the repair bills have been paid. If your vehicle has not been repaired, state where it is presently located and its condition. 13. Identify by date, description, and source any medical records and any other records or documents of any kind in your or your Medical records are obviously critical in this kind of case. The descriptions attorney's possession or control that relate in any way to this you get will be used to send occurrence and the injuries and damages you claim resulted from this production requests to the plaintiff occurrence. and subpoenas to third-party sources. p 529 P 530 14. For each expert expected to testify at trial, state: This interrogatory tracks the (a) expert's full name, address, and professional qualifications; language of Rule 33. (b) the subject matter on which the expert is expected to testify; (c) the substance of the facts and opinions to which the expert is expected to testify, and (d) a summary of the grounds of each opinion. Dated: February 3, 2023 William Sharp William Sharp Attorney for DefendantDEFENDANT'S INTERROGATORIES TO PLAINTIFF Interrogatories will usually be the first Pursuant to Rule 33 of the Federal Rules of Civil Procedure, defendant discovery device the parties serve on each other. Smith requests that plaintiff Jones answer the following interrogatories under oath, and serve them on the defendant within 30 days: In this example, the defendant served 1. Describe the personal injuries you received as a result of the interrogatories on plaintiff two weeks after answering the complaint. (Many occurrence described in the complaint (hereafter "this occurrence") defendants serve interrogatories with 2. State the full names and present addresses of any physicians, the answer.) osteopaths, chiropractors, and other medical personnel who treated you as a result of this occurrence, each such person's areas of specialty, the dates of each examination, consultation, or appointment, the amount of each such person's bill, and whether each bill has been Note how each interrogatory deals paid. with a separate, defined category and 3. Were you confined to a hospital or clinic as a result of this asks for all relevant data for the category. This will usually generate occurrence? If so, state the name and address of each such hospital Of more complete answers. It also gives clinic, the dates of your confinement at each facility, the amount of the answering party the opportunity each such facility's bills, and whether each bill has been paid. of answering the interrogatory by 4. Have you incurred other medical expenses, other than these producing the relevant records that contain the answers. requested in Interrogatory Nos. 2 and 3, as a result of this occurrence? If so, state each expense incurred, the nature of each expense, when the expense was incurred, to whom it was incurred, and whether each expense has been paid. 5. Have you incurred any expenses as a result of this occurrence other than medical expenses? If so, state the nature of each expense, the date incurred, the amount of each