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Interrogatory Topics
Select the categories of questions you want to include in this set of interrogatories.
Names, addresses, and corporate structure
How the accident occurred, defendant's version
Logs, inspections, and repair history of the truck
Identifying passengers, witnesses, and recorded statements
Policy limits, carriers, and umbrella policies
Hiring practices, training records, and CDL status
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IN THE Circuit Court OF [County], [State]
[Plaintiff Name],
Plaintiff,
v.
[Defendant Name],
Defendant.
CASE NO. [Case Number]
TO: [Defendant], by and through their attorney of record.
Pursuant to the applicable Rules of Civil Procedure, Plaintiff, [Plaintiff Name], requests that Defendant, [Defendant], answer the following Interrogatories separately, fully, in writing, and under oath, within thirty (30) days of service hereof.
Instructions
- These interrogatories are continuing in character. If you obtain further information, you must supplement your answers.
- If you object to an interrogatory, state the specific basis for the objection and answer the remainder of the interrogatory.
- "You" or "Your" refers to the Defendant answering these interrogatories, including all agents, employees, and representatives.
Interrogatories
INTERROGATORY NO. 1: State your full legal name, any other names you have used in the past ten years, your current residential address, business address, and date of birth or state of incorporation.
INTERROGATORY NO. 2: Identify all persons who assisted in preparing the answers to these interrogatories, stating their names, addresses, and relationship to you.
INTERROGATORY NO. 3: Describe in detail your version of how the subject accident occurred, including the speeds, lanes of travel, and points of impact for all vehicles involved.
INTERROGATORY NO. 4: Do you contend that the Plaintiff, or any third party, caused or contributed to the cause of the collision? If so, state every fact upon which you base this contention.
INTERROGATORY NO. 5: Describe the commercial motor vehicle you were operating at the time of the collision, including the year, make, model, VIN, and owner of the tractor and trailer.
INTERROGATORY NO. 6: Identify any and all mechanical defects, maintenance issues, or repairs performed on the tractor or trailer involved in the accident within the six (6) months prior to the collision.
INTERROGATORY NO. 7: Identify all persons known to you who witnessed, or claim to have witnessed, the collision or the events immediately preceding or following it.
INTERROGATORY NO. 8: Identify any statements (written, recorded, or oral) obtained from any party or witness regarding the subject collision, including who took the statement and when.
INTERROGATORY NO. 9: Identify all liability insurance policies (including primary, excess, and umbrella policies) that may provide coverage for the damages claimed in this lawsuit, including the name of the insurer, policy number, and policy limits.
Respectfully submitted,
[Plaintiff Name]
Attorney for Plaintiff