Defendant to Plaintiff Interrogatories

1. State your correct legal name and any other names by which you have ever been known, address, marital status, age and occupation, both now and at the time of the incident.

2. List the names and addresses of all witnesses, or persons believed or known by you to have any knowledge concerning facts about the incident.

3. List each of the following:

   a. The names and addresses of those persons who have given to you, your attorney or any person, firm or corporation acting on your behalf, any statements, accident reports, voice recordings, medical proof of claim forms, reports or memoranda in any way concerning the incident

   b. The date of each such statement, accident report, voice recording, medical proof of claim form, report or memorandum

   c. The name, telephone number, and address of the person, firm or corporation who now has possession of same.

4. State the name, address or other information concerning the location of every person known or reasonably believed by you, your agent, investigators or other representatives to have knowledge, information or possession of any map, picture, photograph, drawing or other document about any issue or fact concerning the incident.

5. Did you give a statement or provide information to assist in the preparation of an accident report to any person, firm or corporation regarding this incident? If so, specify:

   a. The date that each such statement was given

   b. The name, address and occupation of the person to whom and for whom each such statement was given

   c. The name and address of the person, firm or corporation having possession of each statement.

6. Have you ever been convicted of, or pleaded guilty or nolo contendere to any criminal offense? If so, specify:

   a. The date of each such conviction or plea

   b. The court and state of each such conviction or plea

   c. The nature of each offense

   d. The disposition of each charge.

7. Identify all persons whom you intend to call as expert witnesses at trial, and for each such expert specify:

   a. The subject matter on which he or she is expected to testify

   b. The substance of the facts and opinions to which he or she is expected to testify

   c. A summary of the grounds for each opinion to which he or she will testify.

8. Identify all other experts consulted or engaged by you, your attorney or your agents.

9. State whether there exists (and, if so, the contents of) any insurance agreement under which any person carrying on an insurance business may be liable to satisfy part or all of a judgment which may be entered in this action or to indemnify or reimburse you for payments made to satisfy such a judgment.

10. Do you contend that the defendant failed to exercise due care and, if so, state the facts on which you rely to support that contention.

11. Describe in detail how the incident occurred, giving all facts concerning the details of the events before, at the time of, and after the incident which you believe had any bearing on the incident.

12. Specify the time, place and substance of any...