1-12 Sample Discovery Demands

• Jurisdiction: United States

1-12 Sample Discovery Demands³⁵³

1-12:1 Sample Interrogatories (Plaintiff)

1. If you denied, neither admitted nor denied, or gave any qualified answer other than an admission, to any of the allegations contained in the Complaint, state the facts and circumstances upon which you base said answer.
2. Are you board certified and/or a specialist in any area of law? If so, state the area of certification or specialization, the date of certification or specialization, the date(s) of renewal (if any), and whether this information was ever communicated to Plaintiff.
3. Describe any and all policies of insurance that you believe cover, or may cover, you for the allegations set forth in Plaintiff's complaint, detailing as to such policies: the name of the insurer, number of the policy, the effective date of the policy, the available limits of liability, and the name and address of the custodian of the policy.
4. State all facts upon which you rely for each affirmative defense in your answer.
5. Do you contend any person or entity other than you is, or may be, liable in whole or part for the claims asserted against you in this lawsuit? If so, state the full name and address of each such person or entity, the legal basis for your contention, the facts or evidence on which your contention is based, and whether or not you have notified each such person or entity of your contention.
6. List the names and addresses of all persons who are believed or known by your agents, your attorneys, or you to have any knowledge concerning any of the issues in this lawsuit and specify the subject matter of their knowledge.
7. If your law firm or you received any monies from Plaintiff, state the amount, the date received, the person or entity on whose behalf said monies were received, and the method of payment.
8. Have you heard, or do you know about, any statement or remark made by or on behalf of any party to this lawsuit, other than yourself, concerning any issue in this lawsuit? If so, state the name and address of each person who made the statement or statements, the name and address of each person who heard it, and the date, time, place, and substance of each statement.
9. Please state if you have ever been a party, either as plaintiff or defendant, in a lawsuit other than the present matter within the last ten (10) years, and if so, state whether you were plaintiff or defendant, the nature of the action, the date and court in which such suit was filed, and the disposition or

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