Demand for Bill of Particulars

[Caption]

DEMAND FOR BILL OF PARTICULARS

Defendant [Name], by and through [his/her] attorney, [Name of Attorney], brings this demand for a bill of particulars, pursuant to 735 ILCS 5/2-607, because [he/she] is unable to respond to plaintiff [Name]’s complaint in the following respects:

1. Plaintiff alleges that [he/she] fell in a hole on defendant’s premises and injured [himself/herself].

2. In plaintiff’s complaint, plaintiff alleges that [he/she] “fell in a hole near 70 E. 33^rd Street.” (Paragraph 4, Count I)

3. Defendant [Name] is unable to answer the allegation because it is wanting in detail.

   Accordingly, defendant [Name] seeks to have plaintiff answer the following question:

1. Describe in detail the location of the defect on defendant’s property that caused plaintiff to fall. Give its location in terms of measurements from fixed objects in...