Purpose:For you to draft a set of interrogatories and requests for production

Outcome: Draft and examine correspondence, forms, and pleadings used in the steps of a civil lawsuit.

Even though Interrogatories need to be in pleading format, they are NOT filed with the court.

I have attached a Discovery checklist below.When working on a lawsuit it is important to keep track of your discovery requests for each case.That way you can keep track of when you sent out various requests, when they were returned, or if you need to set a motion to compel to get the answers/documents.You should also put reminders in your calendar of the return due dates.For this class it may seem stupid to do this step and I agree but when you are working in a law firm you will have 50 to 100 cases all in different stages of litigation.Unless you have a perfect memory you will need a tracking system.This document I attached isn't perfect but it worked for me.

The sample interrogatories for an auto accident, that are attached below, are some common questions generally used in a personal injury MVA (motor vehicle accident) case.This set has too many questions.Part of your assignment is to look up the maximum number of interrogatories that can be served per set.Once you know that answer, you should go through and pick that number of interrogatories and requests for production for the set you are to draft.

Hint:If you ask the interrogatory:What police department, if any, responded to the scene of the accident?, then the request for production:Produce a copy of the police report from the answer to interrogatory (put in #), should follow.

Not all of the questions or requests in the sample set are relevant to our case, take your time and choose wisely.You must have at least 15 interrogatories and 5 requests but feel free to have as many as the court rules allow.

I would suggest that you start with your template then copy and paste the info from Interrogatory doc.Once you have your form, copy and paste individual interrogatory questions and requests for production from the sample set into your pleading.Make sure your rogs are numbered correctly.

The name of the pleading is

PLAINTIFF'S FIRST SET OF INTERROGATORIES AND PRODUCTION REQUESTS TO DEFENDANT (it is at least 2 lines)

For the footer:1st set of Interrogatories - (insert page #)

Assignment:

Refer to Project 1.7on Assignment Handout for Instructions.

AutoSave Off Interrogatories - Sample Set of Auto Rogs (8) - Compatibility Mode - Word Search sarah hassan SH X File Home Insert Draw Design Layout References Mailings Review View Help Grammarly PDFelement Share Comments O Arial v 8 A A Aav AaBbCCI AaBbCCI AaBbCCI E = Editing 1 Caption 1 Normal 1 No Spac... Editor Open Paste Dictate B I U ab X. x2 A v Grammarly Clipboard Font Paragraph Styles Voice Editor Grammarly to the time of trial, the undersigned will move at trial to exclude from evidence any filmed materials. SAMPLE SET OF AUTO INTERROGATORIES information known to or in the possession of said party or parties, their attorneys, their The terms "identify," "identification" and "identity" when used in reference to SUPERIOR COURT OF WASHINGTON FOR COUNTY liability insurers, and their attorneys' and liability insurers' agents documents means to state the nature of each document (e.g., item of correspondence, NO These are also requests for production served upon you in accordance with Civil ile, contract, etc.) in detail sufficient to enable it to be produced on motion or request, the Rule 34. These requests are directed to the above named party or parties and to their specific location of the document (e.g., address, building name, room number, etc.), the Plaintiff, PLAINTIFF'S FIRST DISCOVERY REQUESTS TO DEFENDANT attorneys, and extend to all documents in the possession of said party or parties, their ull name, address and telephone number of the individual having physical possession and attorneys, their liability insurers, and their attorneys' and liability insurers' agents. It is control of the document, and where the document may be made available for inspection Defendants. ) requested that documents responsive to these requests be produced for inspection and and copying upon motion or request. copying at the offices of Pence & Dawson, 3000 Smith Tower, 506 Second Avenue, The terms "identify," "identification" and "identity" when used in reference to a TO Seattle, Washington, 98104, on September 1, 1991, or such other time to which the natural person means to state his or her full name, present address, telephone number, AND TO: His Attorney. parties mutually agree. employer and position. Please respond to each of the following discovery requests separately and fully if objection is made to any interrogatory or request for production, you must set The terms "identify," "identification" and "identity" when used in reference to a under oath within thirty days of the date of service and return the original to this office. forth in detail pursuant to the Civil Rules the reason and basis for the objection. business or other entity means to state the entity's full name, present address, telephone Type responses in the spaces provided, adding pages if additional space is required. DATED at Washington, this _ day of_ , 19_ number, and position of the individual authorized to speak on behalf of the entity with These are interrogatories served upon you in accordance with Civil Rules 26, 33 (law firm) respect to the subject matter involved and 37. These interrogatories are continuing to the extent required by CR 26(e). If 1. INTERROGATORY: Prior to responding to these discovery requests, have you By: thoroughly researched and identified every document and made inquiry of every information is not available within the time limits of the Civil Rules, you must answer each WSBA # employee or agent having knowledge of the information and subject matter sought Attorneys for Plaintiff y these discovery requests? interrogatory as fully as possible within the time limit and furnish additional information DEFINITIONS RESPONSE when it becomes available. If there are any additions, deletions or changes in the answers As used in these discovery requests, the following definitions apply: 2 INTERROGATORY: Please identify by name, address, telephone number, or information provided at any time prior to trial, you are specifically requested to employer and job title each person who was consulted or who assisted in the The term "document" is intended to include without limitation all official and answering of these discovery requests, or who furnished information which was immediately so inform the plaintiff. If additional information is discovered between the time used in answering them. of making these answers and the time of trial, these interrogatories are directed to that personal communications, reports, memoranda, notes, minutes, diaries, transcripts, RESPONSE: information. If such information is not seasonably furnished within a reasonable time prior working papers, telegrams, letters, papers, charts, drawings, graphs, photographs publications, accounting materials, statements, and all other written, printed, typed orCASE DISCOVERY CHECKLIST FOR LITIGATION Client: Case Heading: Cause No.: Judge: Trial Date: Discovery Document Drafted Sent Answer Diaried interrogatories Requests for Admissions PHS - if arbitrated Depositions ER904 Submissions Subpoenas AutoSave O Off) Interrogatories - Sample Set of Auto Rogs (8) - Compatibility Mode - Word Search sarah hassan SH File Home Insert Draw Design Layout References Mailings Review View Help Grammarly PDFelement Share Comn - v E O Arial v 8 A A Aav AaBbCCI AaBbCCI AaBbCCI Editing Editor Open Paste 1 Caption 1 Normal 1 No Spac... Dictate U A v Grammarly B I ab X. DVA v Clipboard Font Paragraph Styles Voice Editor Grammarly RESPONSE: 3. INTERROGATORY: Please state: 6. INTERROGATORY: As to each of your employment positions (including self Your full name employment) for the past 10 years, please state chronologically: Your date and place of birth C. Your residence address and telephone number a. Inclusive dates of employment Your social security number; Name, address and telephone number of employer 9. INTERROGATORY: Have you ever been convicted of a felony, gross Name, address and telephone number of your employer, if any; C. Name, address and telephone number of immediate supervisor(s) misdemeanor, or misdemeanor? If so, please state: Any and all of the names you have used during your lifetime and the dates d . Job title and nature of duties you performed; and localities where used Reason employment terminated. Offense charged Offense you were found to have violated; RESPONSE: RESPONSE: Date violation was found or established; Court and cause number Sentence imposed Sentence served RESPONSE 4. INTERROGATORY: As to each of your marriages, if any, please state: 7. INTERROGATORY: As to each school you have attended or through which you Inclusive dates of marriage; have pursued studies, please state chronologically: Present name, address and telephone number of spouse; Name, address and telephone number of spouse's present employer Name, address and telephone number Whether marriage terminated and, if so, how terminated. Inclusive dates of attendance di Course of study: RESPONSE Date and type of degree conferred. 10. INTERROGATORY: Have you ever been a party to a legal action other than the instant action? If so, please state as to each action: RESPONSE: Date the action was filed; Title of the action; Nature of the action; Court and cause number of the action; 5. INTERROGATORY: As to each of your residences for the past 10 years, please Disposition of the action state chronologically: Name, address and telephone number of your attorney(s) Name, address and telephone number of attorney(s) for all other parties. Inclusive dates of residence; 8. INTERROGATORY: Were you ever in any branch of the military? If so, please Street address' state: RESPONSE: Present name, address, telephone number and nature of relationship of each person with whom you resided. a. Dates of service; b. Branch RESPONSE Rank at discharge; Type of discharge.AutoSave . Off Interrogatories - Sample Set of Auto Rogs (8) - Compatibility Mode - Word O Search sarah hassan SH File Home Insert Draw Design Layout References Mailings Review View Help Grammarly PDFelement Share Con O Arial v 8 A A Aav AaBbCCI AaBbCCI AaBbCCI E Editing Editor 1 Normal Open Paste 1 Caption 1 No Spac... Dictate B I U ab X 2 x2 DVA Grammarly 91 Clipboard Font A Paragraph IN Styles Voice Editor Grammarly identified in response to the preceding interrogatory. Amount of deductible on each coverage; Policy period coverage, 11. INTERROGATORY: Please state as follows as to each statement known to you RESPONSE Policy number. regarding the allegations contained in plaintiff's complaint or the subject matter of this lawsuit, regardless of whether you assert that the statement is discoverable. RESPONSE: (For purposes of this interrogatory, a statement is a written statement signed or otherwise adopted or approved by the person making it, or a stenographic, mechanical, electrical or other recording or transcription that is a substantially verbatim recital of an oral statement by the person making it.): a Name, address, telephone number, employer and job title of the person who 14 INTERROGATORY: If any surveillance of the plaintiff has been performed on gave the statement defendant's behalf. 17. REQUEST FOR PRODUCTION: Please produce all insurance and indemnification b Name, address, telephone number, employer and job title of the person who agreements identified in response to the preceding interrogatory, (including all took the statement State the times and places of all surveillance; declaration pages, endorsements and amendments) in force at the time of the Date of the statement Identify by name, address, telephone number, employer and job title each incident. Form of the statement (e.g., whether handwritten, recorded, transcribed, person who participated in the surveillance; etc.); Identify all documents, photographs, or videotapes produced by the RESPONSE: Subject matter of the statement; surveillance, and identify all custodians thereof. If you assert that the statement is not discoverable, state your basis for that position RESPONSE Identify by name, address, telephone number and job title each person who has knowledge of the content of the statement or who has possession of the statement. 18. INTERROGATORY: Have any of the insurers or indemnitors identified in your response to the preceding interrogatories denied in whole or in part coverage or RESPONSE: ndemnification for any of plaintiff's claims, or accepted defense of this action upon a reservation of rights? If so, please state as to each 15. REQUEST FOR PRODUCTION: Please produce all documents, photographs, or videotapes identified in response to the preceding interrogatory. Name, address and telephone number of the insurer or indemnitor; Contract language upon which the insurer or indemnitor bases its denial of RESPONSE coverage, indemnification or reservation of rights C Reasons for the insurer's or indemnitor's denial of coverage, indemnification or reservation of rights RESPONSE: 12. INTERROGATORY: Please identify (see definition section) each photograph, motion picture, videotape, slide, drawing, diagram, map, or other graphic representation pertaining to the subject matter of this lawsuit. 16. INTERROGATORY: Do any insurance or indemnification policies exist that may satisfy part or all of a judgment that may be entered in this action; or to indemnify or RESPONSE: reimburse for payments made to satisfy such judgment? If so, please state as to each insurance agreement or policy its complete contents, including: Name, address and telephone number of insurer or indemnitor Name, address and telephone number of each named insured or 19. INTERROGATORY: Does any oral or written agreement exist which requires any indemnitee party to obtain approval prior to entering a settlement, or which in any way limits Each type of coverage provided any party's ability to enter a settlement? If so, please identify all parties to each 13. REQUEST FOR PRODUCTION: Please produce all graphic representations Limits of each type of coverage provided; such agreement and state in detail the terms of the agreement.AutoSave . Off Interrogatories - Sample Set of Auto Rogs (8) - Compatibility Mode - Word O Search sarah hassan SH File Home Insert Draw Design Layout References Mailings Review View Help Grammarly PDFelement Share Commer O Arial v 8 A A Aav AaBbCCI AaBbCCI AaBbCCI IA E E = EV Editing Editor Open Paste 1 Caption 1 Normal 1 No Spac... Dictate B I U ab Grammarly X , x2 Clipboard Font Paragraph Styles Voice Editor Grammarly RESPONSE: RESPONSE: 23. INTERROGATORY: State how, when, and where the automobile collision giving rise to this action took place, being specific as to the date, hour and your recollection of the events surrounding this incident. RESPONSE 27. INTERROGATORY: Please state the name, address and telephone number of the legal owner of the vehicle you were driving at the time of the collision. RESPONSE: 20. REQUEST FOR PRODUCTION: Please produce for inspection and copying all documents identified in response to the preceding interrogatory. RESPONSE 24. INTERROGATORY: Were you familiar with the area in which the collision happened? If so, state the degree of familiarity and the reason therefore. RESPONSE: 28. INTERROGATORY: State with particularity any and all work that was performed upon your vehicle, either by you, or another party in the year prior to the date of the collision. 21. INTERROGATORY: Do any oral or written agreements exist allocating or RESPONSE: apportioning responsibility for payment of any settlement or judgment that may be made or entered in this action? If so, please identify all parties to each such agreement, state in detail the terms of the agreement, and state the date the agreement was made. 25. INTERROGATORY: As to the vehicle you were operating at the time of the collision involved in this action, state the following: RESPONSE: Make, model and year The gross weight; When and where you purchased said vehicle; 29. REQUEST FOR PRODUCTION: Please produce all invoices, work orders and bills How long in weeks or months you had been driving said vehicle. for work performed upon your vehicle in the year prior to the date of the collision. RESPONSE RESPONSE: 22. REQUEST FOR PRODUCTION: Please produce for inspection and copying all documents identified in response to the preceding interrogatory. RESPONSE: 26. INTERROGATORY: Please state the name, address and telephone number of the registered owner of the vehicle you were driving at the time of the collision. 30. REQUEST FOR PRODUCTION: Please produce all invoices, work orders and bills for work performed upon your vehicle since the date of the collision.AutoSave Off Interrogatories - Sample Set of Auto Rogs (8) - Compatibility Mode - Word Search sarah hassan SH File Home Insert Draw Design Layout References Mailings Review View Help Grammarly PDFelement Share Comment O Arial v 8 A A Aav AaBbCCI AaBbCCI AaBbCCI CA = EV Editing Editor Open Paste 1 Caption 1 Normal 1 No Spac... Dictate B I U ab x 2 A v A Grammarly Clipboard Font Paragraph Styles Voice Editor Grammarly d. Their position in the car. RESPONSE: RESPONSE: RESPONSE INTERROGATORY: At the time of the collision, did you own a pair of eyeglasses or other corrective lenses? If so, were you wearing them at that time? 31. INTERROGATORY: If the collision was investigated by the police, did you make a RESPONSE statement to the police regarding said collision? If so, set forth the statement given. 34. INTERROGATORY: Please state: RESPONSE: If you were the operator of a motor vehicle at the time of the collision giving rise to this lawsuit, state whether you had in effect at the time of the collision a current and valid operator's license; b. State whether said operator's license contained any driving restrictions, and 38. INTERROGATORY: Was the vehicle you were driving equipped with seat belts? If if so, the nature of the restrictions so, were you wearing a seat belt at the time of the collision? C. If the operator's license contained any restrictions, state whether you were RESPONSE: complying with said restrictions at the time of the collision. 32. INTERROGATORY: After the collision in question did you make a statement to any witnesses or other individuals regarding said collision? If so, set forth the RESPONSE statement given along with the following: 35. REQUEST FOR PRODUCTION: Please produce a photocopy of the operator's d. Whether or not you complained of any injuries license identified in response to the preceding interrogatory. If so, state in detail what injuries were complained of. RESPONSE: RESPONSE: 39. REQUEST FOR PRODUCTION: Please produce copies or negatives of photographs of the vehicle which defendant was driving at the time of the collision showing the damage to said vehicle as a result of the collision. RESPONSE: 36. INTERROGATORY: Have you ever had a driver's license denied, suspended, canceled or revoked? If so, please state: 33. INTERROGATORY: If you were not alone in your car at the time of the collision, please state: a. The name of the state denying, suspending, canceling or revoking such license a. The name(s) of the person(s) with your The date of such denial, suspension, cancellation or revocation; and Their relationship to your The reasons therefore. 40. REQUEST FOR PRODUCTION: Please produce copies or negatives of Their addresses photographs of the vehicle which plaintiff was driving or riding in at the time of theAutoSave . Off Interrogatories - Sample Set of Auto Rogs (8) - Compatibility Mode - Word Search sarah hassan SH X File Home Insert Draw Design Layout References Mailings Review View Help Grammarly PDFelement Share Comments O Arial v 8 A A Aav AaBbCCI AaBbCCI AaBbCCI EV Editing Editor Paste 1 Caption 1 Normal Open 1 No Spac... Dictate B I U ab x2 A Grammarly T Clipboard Font Paragraph Styles Voice Editor Grammarly collision showing the damage to said vehicle as a result of the collision. 44. INTERROGATORY: Pursuant to Civil Rule 26, please identify each person whom RESPONSE: you expect to call as an expert at the time of trial. YOUR FAILURE TO FULLY AND TIMELY ANSWER THIS INTERROGATORY WILL RESULT IN PLAINTIFF OBJECTING TO THE USE OF SUCH EXPERT AT TIME OF TRIAL. As to each 47. INTERROGATORY: Please identify by name, address, telephone number, expert, please state: employer and job title each person believed to have any information concerning the injuries or losses claimed by the plaintiff. d Expert's full name, job title, address and telephone number, Name, address and telephone number of expert's employer, if any; RESPONSE: 41. INTERROGATORY: Please identify by name, address, telephone number, Whether any written reports have been furnished by the expert to defendant employer and job title each witness to the incidents or to the scene of the incidents and, if so, the dates thereof alleged in plaintiff's complaint. d. Subject matter on which the expert has been consulted or is expected to testily RESPONSE: e Substance of the facts and opinions to which the expert is expected to testify f A summary of the grounds for each opinion to which the expert is expected to testify 48. INTERROGATORY: Do you allege that there exist any persons or entities that g. A statement of the expert's qualifications to testify in this action. have caused or contributed to plaintiff's damages who are not specifically named as parties to this action? If so, please state as to each: RESPONSE: Name, address and telephone number of the person or entity All facts upon which you base allegation; 12. INTERROGATORY: Was the occurrence complained of in this action investigated Name, address, telephone number, employer and job title of each person by any law enforcement or regulatory agency? Is so, please state: having knowledge concerning allegation; d Identify all documents pertaining to, evidenceng or supporting allegation, and Name, address and telephone number of agency identify all custodians thereof. Identify all documents pertaining to or evidenceng investigation and identify all custodians thereof. RESPONSE 45. REQUEST FOR PRODUCTION: Please produce all reports identified in (Espouse. RESPONSE: to the preceding interrogatory. RESPONSE 43. REQUEST FOR PRODUCTION: Please produce all documents identified in response to the preceding interrogatory. 49. REQUEST FOR PRODUCTION: Please produce all documents identified in response to the preceding interrogatory. RESPONSE: RESPONSE 46. REQUEST FOR PRODUCTION: Please produce a curriculum vitae or resume of each expert witness identified in response to the preceding interrogatory. 50. INTERROGATORY: Do you allege that the plaintiff was under the influence of RESPONSE intoxicating liquor or drugs which contributed to more than 50% of plaintiff's injuries or damages within the meaning of RCW 5.40.060? If so, please state as follows:AutoSave . Off Interrogatories - Sample Set of Auto Rogs (8) - Compatibility Mode - Word Search sarah hassan SH X File Home Insert Draw Design Layout References Mailings Review View Help Grammarly PDFelement Share Comments a - v O Aria v 8 A A Aav AaBbCCI AaBbCCI AaBbCCI Editing Editor Open Paste 1 Caption 1 Normal 1 No Spac... Dictate B I U ab X 2 x2 A ~ A v Grammarly Clipboard Font Paragraph Styles Voice Editor Grammarly All facts upon which you base allegation; response to the proceeding interrogatory. believed to have knowledge concerning allegation; Name, address, telephone number, employer and job title of each person C. Identify all documents pertaining to, supporting or evidenceing allegation, and having knowledge concerning allegation; RESPONSE: identify all custodians thereof. Identify all documents pertaining to, evidenceng or supporting allegation, and identify all custodians thereof. RESPONSE: RESPONSE 54. INTERROGATORY: You allege in your Answer that plaintiff was contributorily negligent. Please state as to this allegation: 57. REQUEST FOR PRODUCTION: Please produce all documents identified in 51. REQUEST FOR PRODUCTION: Please produce all documents identified in All facts upon which you base allegation; response to the preceding interrogatory. response to subsection c of the preceding interrogatory. Name, address, telephone number, employer and job title of each person believed to have knowledge concerning allegation; RESPONSE: RESPONSE C. Identify all documents pertaining to, supporting or evidenceing allegation, and identify all custodians thereof. RESPONSE: 58. INTERROGATORY: Did you suffer from any physical defect at the time of the occurrence complained of in this action? If so, please state as to each physical 52. INTERROGATORY: Do you allege that the plaintiff was engaged in the defect: commission of a felony at the time of the occurrence which was a proximate cause 55. REQUEST FOR PRODUCTION: Please produce all documents identified in of plaintiff's damages within the meaning of RCW 4.24.420? If so, please state as response to the preceding interrogatory. d. A description of defect follows: Whether the defect affected you in any way and, if so, in what way and to RESPONSE: what extent. a. The felony claimed to have been committed All facts upon which you base allegation; RESPONSE: C . Name, address, telephone number, employer and job title of each person having knowledge concerning allegation; d Identify all documents pertaining to, evidenceng or supporting allegation, and identify all custodians thereof. RESPONSE: 56. INTERROGATORY: You allege in your Answer that plaintiff failed to mitigate his 59. INTERROGATORY: Had you taken any drugs or medications in the 48 hour period damages. Please state as to this allegation: prior to the occurrences complained of in this action? If so, please state as to each drug or medication: All facts upon which you base allegation; 53. REQUEST FOR PRODUCTION: Please produce all documents identified in Name, address, telephone number, employer and job title of each person Name, quantity and strength of drug or medication taken;AutoSave . Off Interrogatories - Sample Set of Auto Rogs (8) - Compatibility Mode - Word Search sarah hassan SH X File Home Insert Draw Design Layout References Mailings Review View Help Grammarly PDFelement Share Comments O Arial v 8 A A Aav AaBbCCI AaBbCCI AaBbCCI EV Editing Editor Paste 1 Caption 1 Normal 1 No Spac... Open Dictate B I U v ab x2 A Grammarly T Clipboard Font Paragraph Styles Voice Editor Grammarly Time of dosages; Whether you were affected physically or mentally by the drug or medication and, if so, in what way and to what extent. 62. INTERROGATORY: In order to enable plaintiff to comply with RCW 11.40.011 and other laws requiring plaintiff to take action to preserve his rights in the event of the RESPONSE: death of a defendant, please advise plaintiff by amended answer to these discovery requests of the: 60. INTERROGATORY: Had you consumed any alcoholic beverages within the 24 Name of the defendant that died; hour period prior to the occurrences complained of in this action? If so, please a. Date and place of death: state C . 65. d County and cause number of the probate proceedings, if any REQUEST FOR PRODUCTION: Please produce all documents identified in Name, address, and phone number of the personal representative and response to the preceding interrogatory. Name, type and quantity of alcoholic beverage consumed; attorney for the estate, if any. Time period during which you consumed beverages; RESPONSE Name, address and telephone number of each person in your company or RESPONSE near you at the time you consumed each beverage; 66 d INTERROGATORY: Please identify any documents sought by the above requests Whether you were affected physically or mentally by the beverage and, if so, for production which formerly existed, but which no longer exist, or which were in what way and to what extent. formerly in your possession or were available to you, but which no longer are in your possession or available to you. As to each such document, please further RESPONSE state: Title of document b. Name, address, telephone number, employer and job title of the author of 63. INTERROGATORY: Please identify by name, address, telephone number, document employer and job title all persons not previously identified who you or your C. Name, address, telephone number, employer and job title of the recipient of representatives believe have knowledge concerning the allegations of plaintiffs document 61. INTERROGATORY: Are you now or have you ever been under the care of a complaint or the subject matter of this lawsuit, and as to each state the nature of his Date of document physical or mental health care provider for any neurological disorder, psychological or her knowledge. Last known location of document or psychiatric disorder, social adjustment difficulty, or addiction or abuse of alcohol What caused document to be destroyed, leave your possession, or no or drugs? If so, please state as to each condition: RESPONSE: longer be available to you; g. Reason document was destroyed, left your possession, or is no longer Condition for which you were treated available to you' Name, address, telephone number and specialty or qualification of each h Contents of document health care provider from whom you have received care for condition; Dates of treatment; RESPONSE Nature of treatment rendered; Outcome of treatment: Whether condition is now cured: Whether condition was cured as of the date of this collision. 64. INTERROGATORY: Do you, your insurance carrier, your attorneys, or any person employed by you, your insurance carrier or your attorneys have possession of, or RESPONSE: know of the existence of any other documentary material, that is relevant to the subject matter involved in this action; or that you intend to rely upon to support the allegations of claims or defenses; or that concerns the events, instrumentalities, or circumstances from which this accident arose, or that you intend to offer in ATTORNEY'S CR 26 CERTIFICATION evidence at the time of trial? The undersigned attorney certifies pursuant to Civil Rule 26(g) that he or she has RESPONSE:read each response and objection to these discovery requests, and that to the best of his or her knowledge, information, and belief formed after a reasonable inquiry, each is (1) consistent with the Civil Rules and warranted by existing law or a good faith argument for the extension, modification, or reversal of existing law; (2) not interposed for any improper purpose, such as to harass or to cause unnecessary delay or needless increase in the costs of litigation; and (3) not unreasonable or unduly burdensome or expensive, given the needs of the case, the discovery already had in the case, the amount in controversy, and the importance of the issues at stake in the litigation DATED at _ day of 19_ Attorney for Defendant VERIFICATION I declare under penalty of perjury under the laws of the State of Washington that I have read the foregoing responses to Plaintiff's Discovery Requests to Defendant know the contents thereof, and believe them to be true and correct. DATED at this day of 19_AutoSave . Off ) H Interrogatories (11) - Compatibility Mode - Word Search sarah hassan SH X File Home Insert Draw Design Layout References Mailings Review View Help Grammarly PDFelement Share Comments O Times New Roman 10 v A A Aav AaBbCcI AaBbCcI AaBbC Editing 1 Normal 1 No Spac... Heading 1 Editor Open Paste Dictate T U v ab v 2 A A Grammarly Al Clipboard Font Paragraph Styles N Voice Editor Grammarly A. PROCEDURES. For your convenience, you have been served with two copies of F. DEFINITION. The term "publication" as used hereinafter in these Interrogatories refers Interrogatories under CR 33. Please complete these answers within the space provided and, if to the actual act of speaking, writing, printing, distributing, broadcasting, showing, or otherwise IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON needed, add additional pages. Within the time the rules permit, return the original and one copy to conveying the allegedly defamatory comm occurrence" as used hereinafter in IN AND FOR THE COUNTY OF the undersigned these Interrogatories refers to the fact alleging liability of the defendants as set forth in plaintiffs B. SCOPE OF ANSWERS. By use of the pronoun "you" or the noun "plaintiff(s)" or complaint. Plaintiff No. defendant(s)", it is intended that the an ers are to include all information known to each of the INTERROGATORY NO. 1. INTERROGATORIES persons to whom the Interrogatories are directed, their officers, employees, principals, agents, Please identify yourself fully, giving your full name, residence address, age, and attorneys, and investigators. When an Interrogatory calls for the information, which is different for occupation, and if married give the name of your spouse. If the defendant is a corporation, please Defendants, the two defendants, answers as to each defendant should be set out separately. state the office you hold with the defendant corporation. TO: C. DOCUMENT. As used herein, the word "document" shall mean the original and any ANSWER: AND TO: opy, regardless of origin or location, of any book, pamphlet, periodical, letter, memorandum, COMES NOW the Plaintiffs, and in accordance with Rules 33and 34 elegram, report, record, study, handwritten note, map, drawing, working paper, chart, paper, graph, of Civil Rules for Superior Court for the State of Washington, requests the above-named ndex, tape, data sheet or data processing corded, transcribed, punched, INTERROGATORIES DATED defendants to answer the following Interrogatories and Requests for Production separately and fully taped, filmed, photographic or graphic matter, however produced or reproduced, to which you have (law firm) under oath within twenty (20) days of the date of service of these Interrogatories. In answering I have had access at any time. By these Interrogatories, you are re is available to you, not merely D. IDENTIFY OR IDENTITY. As used herein, "identify" or "identity" used in reference WSBA # Attorney for information, which you know of as your personal knowledge. This is intended to include any to an individual person means to state his full name and present address, his present or last known STATE OF WASHINGTON ) information in the possession of any agent, employee, officer or attorney of defendants or any position and business affiliation, and his position and affiliation at the time in question. "Identify" COUNTY OF nvestigator for defendants. or "identity" when used in reference to a document means to state the date and author, type of being first duly sworn upon oath, deposes and says: That he IN ALL OF YOUR ANSWERS, YOU ARE TO STATE THE SOURCE OF document (e.g., letter, memorandum, telegram, chart, etc., etc.) or some other means of identifying is a party to the above-captioned lawsuit; that he has read the foregoing Interrogatories and Answers Thereto; knows the contents thereof and believes the same to be true." DEFENDANTS' INFORMATION AND/ OR THE PARTICULAR RECORD RELIED UPON IN it, and its present location or custodian. If any such document was but is no longer in your GIVING THE ANSWER. possession or subject to your control, state what disposition was made of it. SUBSCRIBED AND SWORN TO before me this day of THESE INTERROGATORIES ARE CONTINUING IN NATURE, AND PLAINTIFFS . TIME/CONSUMING EFFECT. Unless otherwise stated, these Interrogatories cover the 20 HEREBY REQUEST THAT ANY INFORMATION COMING INTO THE POSSESSION OF period from the alleged incident or occurrence to date. However, these Interrogatories shall be Name: DEFENDANTS THAT WOULD CHANGE THE ANSWERS IN ANY WAY BE PROMPTLY deemed to be continuing in the event you discover further information that is responsive to these NOTARY PUBLIC in and for the State of Washington, residing at FURNISHED TO PLAINTIFFS' COUNSEL, IN ANY EVENT NO LATER THAN TWENTY nterrogatories. If further information is discovered, you are to supplement the answers by My commission expires 20) DAYS AFTER RECEIPT OF SUCH INFORMATION. supplemental answer to Interrogatories Responses submitted and certified in compliance with Civil Rule 26(g) this of _day ,20 WSBA # Attorney forState the paragraph from Complaint you are referring to and then either state Admitted, Denied or Defendant lacks sufficient evidence or information to either admit or deny the allegation for each allegation set forth on Complaint. It is set up in Sections like the Complaint but will be |. Answer, ll Affirmative Defenses, l|l Prayer for Relief and Dismissal. 3. Prepare a Certificate of Service (stating documents were sent to Plaintiff's attorney (these pleadings would also be e-filed but for this class we will pretend that was already done. So, on top of pleading write neatly FILED KING COUNTY SUPERIOR COURT and put a date on it). NOTE The defendant's attorney would be procuring release forms from his client but since we already did one for the plaintifl's side you do not have to do these. Proiect 1.7 Interrogatories and Requests for Production Prepare a set of Interrogatories and Requests for Production to he sewed on the defendant. Forms and templates are in Canvas under Discovery but you will have to conform them for this case. I will give more information on this assignment in class. Before starting this project you will need to look up the local rules regarding how many interrogatory questions can he asked at one time. This is why during discovery more than one set of interrogatories is usually sent to the other party. Froiect 1.3 Motion to Compel Assume that the defendant has not answered our interrogatories, prepare a Note for Motion and a Motion to Compel Discovery Requests. Proiect 1.9 Answer to Interrogatories Assume that you are the defendant and answer the interrogatories and requests for production. You can make up any exhibits for production you want as long as they make sense for the case. Pro'ect 1.10 Depositions Prepare a Notice of Deposition for the plaintiff's doctor. Write a memo to the le as to where the deposition is to take place and who the court reporter will be, Then do a certificate of mailing and a letter to the doctor. Then write a letter to the defendant's attorney with a copy of the Notice of Deposition. Pro'ect 1.11 sarah hassan SH X AutoSave . Off ) Pleading Template (22) - Word Search Share Comments File Home Insert Draw Design Layout References Mailings Review View Help Grammarly PDFelement O Times New Roman (Body) v 10 A A Aav AaBbCcDd AaBbCcDd AaBbCcDd = E Editing Editor Open 1 Normal Attorney... Case No. Dictate Grammarly Paste B I U ab X 2 A A AL Styles Voice Editor Grammarly Paragraph Clipboard Font IN THE SUPERIOR COURT OF WASHINGTON IN AND FOR THE COUNTY OF KING Case No.: [Number] 10 00 Plaintiff, [PLEADING TITLE] 10 Defendant [Type body of pleading here.] Dated this [day] of [Month], [year]. 14 15 [Attorney Name] 16 18 28 [PLEADING TITLE] - 1AutoSave . Off Interrogatories (12) - Compatibility Mode - Word Search sarah hassan SH X File Home Insert Draw Design Layout References Mailings Review View Help Grammarly PDFelement Share Comments O Times New Roman 10 A Aav AaBbCcI AaBbCcI AaBbC = Editing Paste 1 Normal 1 No Spac... Heading 1 Editor Open Dictate 3 T U v ab X, v2 A A Grammarly AL Clipboard N Font Paragraph Styles N Voice Editor Grammarly A. PROCEDURES. For your convenience, you have been served with two copies of F. DEFINITION. The term "publication" as used hereinafter in these Interrogatories refers O Interrogatories under CR 33. Please complete these answers within the space provided and, if to the actual act of speaking, writi ing, showing, or otherwise IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON needed, add additional pages. Within the time the rules permit, return the original and one copy to conveying the allegedly defamatory communication. The term "occurrence" as used hereinafter in IN AND FOR THE COUNTY OF the undersigned these Interrogatories refers to the fact alleging liability of the defendants as set forth in plaintiffs' B. SCOPE OF ANSWERS. By use of the pronoun "you" or the noun "plaintiff(s)" or complaint Plaintiffs, No. 'defendant(s)", it is intended that the answers are to include all information known to each of the INTERROGATORY NO. 1. INTERROGATORIES persons to whom the Interrogatories are directed, their officers, employees, principals, agents, Please identify yourself fully, giving your full name, residence address, age, and attorneys, and investigators. When an Interrogatory calls for the information, which is different for occupation, and if married give the name of your spouse. If the defendant is a corporation, please Defendants, the two defendants, answers as to each defendant should be set out separately. state the office you hold with the defendant corporation. TO: C. DOCUMENT. As used herein, the word "document" shall mean the original and any ANSWER: AND TO: opy, regardless of origin or location, of any book, pamphlet, periodical, letter, memorandum, COMES NOW the Plaintiffs and in accordance with Rules 33and 34 telegram, report, record, study, handwritten not map, drawing, working paper, chart, paper, graph, of Civil Rules for Superior Court for the State of Washington, requests the above-named index, tape, data sheet or data proces ten, recorded, transcribed, punched, INTERROGATORIES DATED defendants to answer the following Interrogatories and Requests for Production separately and fully aped, filmed, photographic or graphic matter, however produced or reproduced, to which you have (law firm) under oath within twenty (20) days of the date of service of these Interrogatories. In answering or have had access at any time. By these Interrogatories, you are required to furnish such inf nation as is available to you, not merely D. IDENTIFY OR IDENTITY. As used herein, "identify" or "identity" used in reference WSBA # Attorney for information, which you know of as you al knowledge. This is intended to include any to an individual person means to state his full name and present ad ss, his present or last known STATE OF WASHINGTON ) information in the possession of any agent, employee, officer or attorney of defendants or any position and business affiliation, and his position and affiliation at the time in question. "Identify" COUNTY OF investigator for defendants. I "identity" when used in reference to a document means to state the date and author, type of document (e.g., letter, memorandum, telegram, chart, etc., etc.) or some other means of identifying being first duly sworn upon oath, deposes and says: That he IN ALL OF YOUR ANSWERS, YOU ARE TO STATE THE SOURCE OF is a party to the above-captioned lawsuit; that he has read the foregoing Interrogatories and Answers Thereto; knows the contents thereof and believes the same to be true. DEFENDANTS' INFORMATION AND/ OR THE PARTICULAR RECORD RELIED UPON IN it, and its present location or custodian. If any such document was but is no longer in your GIVING THE ANSWER. possession or subject to your control, state what disposition was made of it. SUBSCRIBED AND SWORN TO before me this _day of THESE INTERROGATORIES ARE CONTINUING IN NATURE, AND PLAINTIFFS E. TIME/CONSUMING EFFECT. Unless otherwise stated, these Interrogatories cover the 20 HEREBY REQUEST THAT ANY INFORMATION COMING INTO THE POSSESSION OF period from the alleged incident or occur occurrence to date. However, these Interrogatories shall be Name: DEFENDANTS THAT WOULD CHANGE THE ANSWERS IN ANY WAY BE PROMPTLY leemed to be continuing in the event you discover further information that is responsive to these NOTARY PUBLIC in and for the State of Washington, residing at _ FURNISHED TO PLAINTIFFS' COUNSEL, IN ANY EVENT NO LATER THAN TWENTY interrogatories. If further information is discovered, you are to supplement the answers by My commission expire (20) DAYS AFTER RECEIPT OF SUCH INFORMATION upplemental answer to Interrogatories Responses submitted and certified in compliance with Civil Rule 26(g) this of 20 WSBA # Attorney for