Interrogatories Sample

1. UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MINNESOTA


Adam Sharp, )
)
Plaintiff, )
)
) File No. 00-0000
v. )
)
AAA Trucking, Inc. )
)
Defendant. )
____________________________________)

FIRST SET OF INTERROGATORIES TO DEFENDANT

To: Defendant AAA Trucking, Inc. and its attorney, Jane Doe, 100 Main Street, Chicago, IL
60601.

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.

1. Please state the full names, current addresses, employment positions and employers of each
and every person who, to your knowledge or to that of your agents, attorneys, or employees,
have knowledge of any of the facts concerning the incident referred to in the Complaint. Identify
all documents which relate to each of these persons and the incident.

2. State the full name, current address and employment position of each person who investigated
on your behalf the matters which are the subject of this suit. Identify each and every document
which relates in any way to this Interrogatory answer.

3. Set forth in full the substance of any admission by a party or by an alleged agent of a party,
and include within your answer the name of the person making each such admission, the date
and time of the admission, and the name and address of all persons present at the time of the
admission. Identify each and every document which relates in any way to each such admission.

4. List the names, addresses, official titles, if any, home and work addresses and telephone
numbers of all witnesses, including expert witnesses, who it is contemplated will be called upon
to testify in support of your position in this action, indicating with respect to each the nature and
substance of the testimony expected to be given and stating the relationship, if any, of the
witness to you.

5. State whether you, your agents, or attorneys have ever seen or have knowledge of any
photographs, videotapes, films, or movies of, or relating to, the incident. If so, state the full

2. name, current address and employment position of each person now in possession of any such
materials. Identify each and every document which relates to every single one of these materials,
as well as the materials themselves.

6. Please itemize in complete and exhaustive detail each and every element of damage which you
claim or contend is associated with the incident. Identify all documents presently in your
possession, or of which you, your agents, servants, employees or attorneys are aware, which in
any way substantiates these damages.

7. If you, or anyone on your behalf, has obtained any statements concerning the accident which
is the subject matter of this lawsuit, describe separately each such statement by setting forth the
name and address of the person who gave it, the name, address and employment position of the
person who took it, the date it was taken, whether it was written or recorded, whether it was
reduced to writing, whether it was signed and the present location of all notes, recordings,
transcripts, or other writings of any kind pertaining to each statement.

8. If you ever prepared, submitted or made any written statements or reports describing the
accident, please state the date of any such statement or report, the substance of the contents of
any such written report, the person to whom the statement or report was made, the present
custodian of the original of the statement and whether a copy of the statement or report is in your
possession or custody.

9. If you have made an insurance claim or have been reimbursed by any insurer for any of the
losses or damages claimed in this suit, state with respect to each such claim or reimbursement the
name and address of the insurer, the policy number under which the claim or reimbursement was
made, the nature of insurance coverage provided, the amount claimed, and the amount of each
reimbursement made. Identify all documents which relate in any way to the claim or
reimbursement.

10. If at the time of the occurrence which is the subject of this suit there was any policy of
liability insurance affording coverage to you or the operator of the automobile which you owned
at the time of the occurrence, state with respect to each such policy the name and address of each
named insured, the name and address of the insurer, the policy number, the limits of bodily
injury and property damages liability protection, and the nature of each coverage defense,
reservation of right and non-waiver agreement, if any, that the insurer has asserted or entered
into with respect to this occurrence.

11. If you claim to have sustained any loss of income as a result of the incident, state the full
amount claimed to have been lost, the sources from which you would have received it, and the
inclusive dates during which you lost it. Please also set forth in complete and exhaustive detail
your analysis of how the loss was computed. Identify all documents which in any way relate to
this claim.

12. If your company has ever pled guilty to or been convicted of any crime that was punishable
by death or imprisonment for one year or more or involved dishonesty or false statement within
the past ten years please state the nature of the offense, the date of false statement within the past

3. ten years, and please state the nature of the offense, the date of your conviction, the county and
state in which you were tried, and the sentence given to you.

13. For every crime for which your company pled guilty or were convicted which was either 1)
punishable by death or imprisonment for one year or more under the law under which you were
convicted, or 2) involved dishonesty or false statement, regardless of punishment, identify the
date of conviction, the court, the sentence, and the date of your discharge from the sentence, if
that has occurred.

14. Please state in complete and exhaustive detail your personal knowledge of how the accident,
which is the subject of this lawsuit, took place, setting forth the events in the order in which they
occurred.

15. Please identify each and every physician, technician, physical therapist, hospital, laboratory,
clinic or other medical person or facility by whom or at which Paul Williams have been
examined, tested or treated during the ten year period immediately preceding the date of the
incident. Include within your answer the inclusive dates during which each such exam, test or
treatment occurred, together with the name, type and/or description of each such examination,
test or treatment and the reason therefor.

16. Please identify each and every physician, technician, physical therapist, hospital, laboratory,
clinic or other medical person or facility by whom or at which Paul Williams has been examined,
tested or treated from the date of the incident up to and including the present date; and include
within your answer the dates of each exam, test or treatment, and the name, type and/or
description of each such examination, test or treatment, and the reason therefor.

17. If Paul Williams has had physical complaints of any kind since the incident, set forth in
complete and exhaustive detail the nature of each such complaint, including the dates and times
of each complaint; and describe the frequency, intensity and duration of each complaint.

18. For every pharmacy that filled prescriptions issued to Paul Williams or on his behalf in the
five (5) years immediately preceding the incident of which you complain, identify the name and
address of the pharmacy, the name and address of the prescribing physician, and of the complaint
or condition you understand the prescription medication or device addressed.

19. If you have been or expect to be a party to any other suit describe completely the nature of
each such suit, claim or proceeding, including the forum, the parties, the date of filing, a brief
description of the injury, disease or disability forming the basis for the claim, and the disposition
of the suit or claim.

20. For every accident in which Paul Williams was ever involved, including but not limited to
motor vehicle accidents, identify the date, place, a description of the damage to both property
and person, the names and addresses of persons involved, and a summary of what happened.

21. With respect to the damage to the vehicle you owned, sate in detail the part or parts damaged,
the extent of damage and the cost of repair.

4. 22. If Paul Williams claim to have sustained any permanent impairment as a result of the
incident, describe each part of Paul Williams claim is permanently impaired by the incident,
stating the degree of each impairment. Identify and state a summary of the qualifications of each
medical expert whom you plan and/or intend to present to testify at trial concerning Paul
Williams’ claim for permanent impairment. For each such expert witness, state the substance of
all facts and opinions to which the witness is expected to testify and a summary of the grounds
for each opinion he will give.

23. If Paul Williams was at any time confined as a result of the injuries sustained in this accident,
please describe in detail the period of time you were confined in any hospital, the period of time
he was confined to bed and the period of time he was confined to his home.

24. Please describe in complete and exhaustive detail any and all injuries, painful symptoms,
and/or congenital defects Paul Williams had suffered before the incident, and further indicate
how recently before the incident you had been treated for such difficulties, by date.

25. Please describe in detail each and every occupational and avocational activity which Paul
Williams was able to perform before the incident that he was unable to perform to any extent as a
consequence of the incident.

26. If you claim or contend that you are entitled to damages for pain and suffering, please list in
precise detail each and every occurrence, symptom or other factor which in any way supports
this claim or contention.

Dated: November 4, 2014


_______________________________
Janet Donnelly
Lucas and Donnelly, L.L.P.
123 Main Street
St. Paul, Minnesota, 55123
Telephone: [phone]