Defendant's "triple threat" discovery propounded to plaintiff employee's spouse

[Style of Case]

DEFENDANT'S FIRST REQUESTS FOR ADMISSIONS, FIRST SET OF

INTERROGATORIES AND FIRST REQUESTS FOR PRODUCTION

OF DOCUMENTS TO PLAINTIFF

TO: Plaintiff _____, by and through [his/her] counsel of record, _____.

Pursuant to the [Federal/Texas] Rules of Civil Procedure, Defendant ____________________ (hereafter "Defendant") submits to you the following discovery.

[INSERT STANDARD INSTRUCTIONS AND DEFINITIONS:

FORM DIS012]

USE NOTE: This set of discovery includes interrogatories regarding expert witnesses. Under the Texas Rules of Procedure 195.1, a party can request information regarding a testifying expert only through a request for disclosure under Rule 194 or through depositions and reports. NOTE: This limitation does not prevent an interrogatory regarding consulting experts where the consulting expert’s mental impressions or opinions have been reviewed by a testifying expert. See Rule195 cmt. 1.

REQUESTS FOR ADMISSIONS

REQUEST FOR ADMISSION NO. :

Admit that the past medical expenses you incurred as a proximate result of the incident are less than $5,000.

RESPONSE:

REQUEST FOR ADMISSION NO. :

If you answered Request for Admission No. 1 with anything other than an unqualified admitted, admit that the past medical expenses you incurred as a proximate result of the incident are less than $10,000.

RESPONSE:

REQUEST FOR ADMISSION NO. :

If you answered Request for Admission Nos. _____ or _____ with anything other than an unqualified admitted, admit that the past medical expenses you incurred as a proximate result of the incident are less than $15,000.

RESPONSE:

REQUEST FOR ADMISSION NO. :

Admit that the future medical expenses _____ you will incur as a proximate result of the incident will be less than $5,000.

RESPONSE:

REQUEST FOR ADMISSION NO. :

If you answered Request for Admission No. _____ with anything other than an unqualified admitted, admit that the future medical expenses you will incur as a proximate result of the incident will be less than $10,000.

RESPONSE:

REQUEST FOR ADMISSION NO. :

If you answered Request for Admission Nos. _____ or _____ with anything other than an unqualified admitted, admit that the future medical expenses you will incur as a proximate result of the incident will be less than $15,000.

RESPONSE:

REQUEST FOR ADMISSION NO. :

Admit that in this lawsuit you seek to recover less than $5,000 for loss of consortium and household services.

RESPONSE:

REQUEST FOR ADMISSION NO. :

If you answered Request for Admission No. _____ with anything other than an unqualified admitted, admit that in this lawsuit you seek to recover less than $10,000 for loss of consortium and household services.

RESPONSE:

REQUEST FOR ADMISSION NO. :

If you answered Request for Admission Nos. _____ or _____ with anything other than an unqualified admitted, admit that in this lawsuit you seek to recover less than $15,000 for loss of consortium and household services.

RESPONSE:

REQUEST FOR ADMISSION NO. :

If you answered Request for Admission Nos. _____, _____, or _____ with anything other than an unqualified admitted, admit that in this lawsuit you seek to recover less than $20,000 for loss of consortium and household services.

RESPONSE:

REQUEST FOR ADMISSION NO. :

If you answered Request for Admission Nos. _____, _____, _____, or _____ with anything other than an unqualified admitted, admit that in this lawsuit you seek to recover less than $25,000 for loss of consortium and household services.

RESPONSE:

REQUEST FOR ADMISSION NO. :

If you answered Request for Admission Nos. _____, _____, _____, or _____ with anything other than an unqualified admitted, admit that in this lawsuit you seek to recover less than $30,000 for loss of consortium and household services.

RESPONSE:

REQUEST FOR ADMISSION NO. :

Admit that the total amount of damages that both you and your spouse have suffered as a proximate result of the incident total exactly $_____.

RESPONSE:

REQUEST FOR ADMISSION NO. :

Admit that the total amount of damages suffered by you and your spouse as a proximate result of the incident, including all past, present and future damages does not exceed $_____.

RESPONSE:

INTERROGATORIES

INTERROGATORY NO. :

If any interviews or statements have been taken from any current and/or former agents, representatives or employees of Defendant, please identify the names of each person who gave a statement and the date the statement was made.

ANSWER:

INTERROGATORY NO. :

With regard to any witness whom you may call as an expert witness at the trial of this lawsuit through live testimony or by deposition, please identify the expert, and for each such expert state the following:

a. The subject matter on which the expert is expected to testify;

b. The substance of the facts and opinions to which the expert is expected to testify; and

c. A summary of the grounds and basis for each and every one of the expert’s opinions.

ANSWER :

INTERROGATORY NO. :

Identify the name, address, and occupation of each expert used for consultation who is not expected to be called as a witness at trial (either through live or deposition testimony) if any expert who may testify has talked to the consulting expert or reviewed any findings, information, reports, calculations, opinions or documents generated by the consulting expert.

ANSWER :

INTERROGATORY NO. :

Please identify each person known to you, your associates, or your attorneys who has knowledge of any relevant facts concerning your injuries, your damages, this lawsuit, or the alleged accident or...