These interrogatories and requests for production are continuing; supplemental answers and documents must be filed pursuant to Fed. Please identify each person who answer these interrogatories and each person (attach pages if necessary) who assisted, including attorneys, accountants, employees of third party entities, or any other person consulted, however briefly, on the content of any answer to these interrogatories. PLEASE TAKE NOTICE that plaintiff Adam Sharp demands answers to the following interrogatories, under oath, pursuant to Rule 33 of the Federal Rules of Civil Procedure. 22. Provided him are sample Interrogatories which may assist team in discovering certain important. 4006 and the Answers must be served on all other parties within thirty (30) days after the Interrogatories are deemed served. Form 2 - GENERAL PERSONAL INJURY NEGLIGENCE - INTERROGATORIES TO DEFENDANT. PLAINTIFF'S FIRST SET OF PATTERN INTERROGATORIES, REQUESTS FOR PRODUCTION OF DOCUMENTS AND REQUESTS FOR ADMISSION TO DEFENDANTS . Please identify any person you expect to call to testify at the time of trial. GENERAL PERSONAL INJURY NEGLIGENCE - INTERROGATORIES TO PLAINTIFF. INTERROGATORIES These interrogatories are served upon you pursuant to O.C.G.A. Instructions to All Parties The defendant might send the plaintiff interrogatories such as: Please list all damages that you claim as a result of the alleged defamation, including type of damages, monetary value, and any supporting documents. for optional use of dorner at eros. Identify the persons involved in the investigation and handling of Plaintiff's claim for insurance benefits arising from damage during Hurricane Ike, and include a brief description of the involvement of each ANSWER: 2. INTERROGATORY NO. State amount paid by claimant for the said motor vehicle. Justia - California Civil Jury Instructions (CACI) (2022) 3931. Was the motor vehicle that the defendant driver was driving at . eBook by E. Robert Wallach. PLAINTIFF'S SPECIAL INTERROGATORIES, SET ONE S ELARZ L AW C ORP. WRITTEN INTERROGATORIES1. 16. In the practice of law, interrogatories are the most commonly method used in discovery, or in the effort to obtain information from an opposing party to a lawsuit. You should only use this form as a guide and delete questions not relevant to your case, as well as add questions you or your client want to ask the Defendant based upon the facts of your case . . The interrogatories under 325.0, Defendant's Contentions, should not be used until the defendant/cross-defendant has had a reasonable opportunity to conduct an investigation or discovery of the other parties' damages. 9: Any DOCUMENTS which afforded liability insurance coverage for the incident which is the subject matter of the PLAINTIFF'S Complaint. Plaintiff asserts she has incurred wage loss, loss of use of property, hospital and medical expenses, general damage, property damage, loss of earning capacity, and miscellaneous related damages. Plaintiff, by and through undersigned counsel and pursuant to Rule 34 Arizona Rules of Civil Procedure, requests that the Defendant produce for inspection, copying, the following documents: Please produce all policies in effect on date of the subject accident ("Collision") by any liability insurance carrier covering, protecting and/or . 7. Clearly . 3. This is a sample set of 28 Interrogatories from Defendant to Plaintiff for use in connection with a vehicle incident, such as an automobile accident. 9: Any DOCUMENTS which afforded liability insurance coverage for the incident which is the subject matter of the PLAINTIFF'S Complaint. In a limited civil case, the plaintiff can ask the defendant only 35 interrogatories. State whether plaintiff has a current property manager's license, and the date on which it was issued. These requests are deemed to be continuing insofar as if any of the above is secured (a) Interrogatories are written questions prepared by a party to an action that are sent to any other party in the action to be answered under oath. (c) The limits of Personal Injury, Property Damage and Medical Payments Coverage on the date of the occurrence mentioned in plaintiff's petition: _____ (d) Attach a copy of the Declaration Page or Certificate of Coverage of such policy of insurance to your answer to these interrogatories. Lite DePalma Greenberg, LLC (Newark) and Gary K. Wolinetz, Esq. ANSWER: 16. ANSWER: 5. DEFINITIONS 2. A copy of any and all photographs and/or videotapes depicting the Plaintiff doing anything. FORM 1. Discovery into these defects breaches damages and repair thereof is. Any and all documents obtained through a request for production of documents or subpoena. Identify all persons answering or supplying information used in answering these Interrogatories. Charles v. Reuck (1960) 179 CA2d 145, 147. Please advice as to what is left on the policy limits after pay out for property damages etc. REV. P. 33, Plaintiff hereby submits the following Interrogatories to Defendant. Pleadings frame the issues of your case and therefore should frame the information you seek in discovery. Plaintiff, by and through undersigned counsel and pursuant to Rule 33 & 33.1, Arizona Rules of Civil Procedure, requests that the Defendant answer, under oath and in writing within thirty (30) days after service, the following Interrogatories: State your name and address or principal place of business, date of birth and social security number. Civil Action No. Also obtain a copy of the application for insurance. example, where a property insurer rescinded a policy on the ground that the application failed to disclose that the property had a swimming pool, the insurer's rescission was undermined by the fact that its underwriting file contained a picture of the property that showed the swimming pool. ANSWER: 4. This Standard Clause contains integrated drafting notes with important explanations and drafting tips. 108 8 At the time of the incident described in the complaint, was the defendant driver engaged in any mission or activity for any other person or entity, including any employer? 23. A complete copy of any incident or accident report concerning the incident referred to in the Plaintiff's Petition. 5. 1. Plaintiff(s) hereby make demand that the Defendant(s) answer the following Interrogatories pursuant to the Pennsylvania Rules of Civil Procedure 4001 et seq. This Standard Clause contains integrated drafting notes with important explanations and drafting tips. Counsel should integrate this Standard Clause into a larger formal set of interrogatories specifically drafted for use in the relevant jurisdiction. Interrogatories Sample 1. . 90-123-ABC PLAINTIFF'S FIRST INTERROGATORIES TO DEFENDANT ACE AUTO DEALERS Plaintiff Paul Purchaser hereby requests that defendant State the names and addresses of any experts you intend to call at the time of trial in support of your case. 8/9/97 1. Form 5 - AUTOMOBILE NEGLIGENCE - INTERROGATORIES TO PLAINTIFF. This information can then be used at trial. subject matter of this action, the PLAINTIFF, or property damage. Produce all correspondence, reports and other records relating to any claim which you have made against any person or entity other than Defendant as a result of the incidents and conduct made the basis of this suit. ANSWER: (a) - (d) None other than the information previously submitted by the attorney for the plaintiff. Please include the name of any other driver or property owner involved, the location of the collision, the date and time of the collision . All property damage estimates rendered for any object belonging to the Plaintiff(s) and/or Defendant(s) which was involved in this alleged accident. 11777 San Vicente Blvd., Suite 702 Los Angeles, California 90049 Tel: 310.651.8685 • Fax: 310.651.8681 with other persons or with property. If repairs were not made to the premises following any complaints or any 3. Once that limit is reached, the plaintiff cannot request any admissions or documents. hereby serves these Requests for Admissions, Interrogatories, and Production of Documents to Plaintiff. b. PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANTS NOW COMES the Plaintiff, INJURED PERSON, by and through his attorneys, ROSENFELD INJURY LAWYERS, and requests the Defendants, RESPONSIBLE PARTIES, answer the following Interrogatories, to be answered, under oath, within the next twenty-eight (28) days. You should only use this form as a guide and delete questions not relevant to your case, as well as add questions you or your client want to ask the Defendant based upon the facts of your case. Plaintiff objects to each document request to the extent that it calls for production of a privilege log for internal documents of Plaintiff. INTERROGATORIES 1. Ans. ANSWER: 6. AUTO OWNERSHIP AND PROPERTY DAMAGE (a) State the name and address of any and all registered or equitable 1: State your full name, any former names or aliases, address, date of birth, marital status and social security number. Once that limit is reached, the plaintiff cannot request any admissions or documents. 2. Section 3. State where plaintiff was coming from and the place of his/her destination at the time of the accident in question. 5. Plaintiff objects to each document request and interrogatory that is overly broad, unduly burdensome, or not reasonably calculated to lead to the discovery of admissible evidence. 8. 11777 San Vicente Blvd., Suite 702 Los Angeles, California 90049 Tel: 310.651.8685 • Fax: 310.651.8681 with other persons or with property. The answer to Interrogatories shall be made under oath by Plaintiff, separately and fully in writing, on or before the 30th day after receipt of such Interrogatories and shall be delivered to Defendant. BAJI 14.20. §9-11-33. Here's how to fill out the required interrogatory forms: Select the proper forms. The Recorder California Appellate Law Group. Florida Rule of Civil Procedure 1.340 - Interrogatories to Parties - provides that a party may serve on any other party written interrogatories. As amended through April 18, 2022. This is a example of a first set of plaintiff's Requests for Admissions in a serious pedestrian accident case in Maryland Circuit Court. Plaintiff reserves the right to modify or amend these responses at any time and as discovery proceeds. subject matter of this action, the PLAINTIFF, or property damage. Pursuant to Fed. They can also be used to ask parties to admit . 10: Any DOCUMENTS identified in any other parties ' Answers to Interrogatories. Sample interrogatories that a defendant may use to seek information from a plaintiff in a common law breach of fiduciary duty action. Interrogatories are a formal set of written questions propounded by one party upon another party. 4. "The Policy" means the insurance policy that is the basis of claims made against Defendant in this . 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