Interrogatories - Premises Liability

General

1. Please state your name, occupation, title, address, and relationship to the parties to this litigation.

2. Please provide the name, address, title, and occupation of each owner of the premises [or home, plant, store, business, mall, field, hotel, etc.] located at _____________________ in the city and state of __________________ .

3. Are you aware of the incident involving the Plaintiff ________________ that occurred on __________, 20 __ ? If your answer is anything other than an unqualified “No,” please set forth the following information specifically and in detail:

   1. Based upon your understanding, please provide a detailed description of the events and circumstances involving the Plaintiff and the subject incident.

   2. Based upon your understanding, please provide a detailed description of the facts and circumstances that led up to, caused or contributed to the subject incident.

   3. What is the basis for your understanding? (Was the information provided to you or did you observe it firsthand?)

   4. To the extent that you have not already done so, please set forth the approximate time of day that the incident occurred and the names and addresses of all of the persons involved in the incident.

4. Are you aware of any procedure for reporting incidents such as the one that involved the Plaintiff on ____________, 20 __ ? If your answer is anything other than an unqualified “No,” please set forth the following information specifically and in detail:

   1. Describe the reporting procedure in detail.

   2. Please set forth the names, addresses, occupations and titles of each person who has a role in the reporting procedure; and please describe each person’s role in detail.

   3. Describe the manner in which the preceding procedures were applied in the Plaintiff’s case.

5. With respect to the incident involving the Plaintiff, are you aware of any writings or written reports? If your answer is anything other than an unqualified “No,” to the extent that you have not already done so, please set forth the following information specifically and in detail for each report and writing:

   1. The title, date, author and each signatory.

   2. The names, addresses, titles, occupations and relationship to the parties of each signatory.

   3. The person or entity to whom the report was directed.

   4. A summary of its contents.

   5. The name, address, title, occupation and relationship to the parties of each person who possesses a copy of the report or is a custodian of the report.

6. Have you [or the Defendant] ever been covered by any contract, agreement or policy of liability insurance? If your answer is anything other than an unqualified “No,” then for each such contract, agreement or policy of insurance, please provide the following information specifically and in detail:

   1. The type of policy [i.e., homeowners, automobile, umbrella, etc.], the policy number, and the type of coverage [i.e., basic, excess, supplemental]. Also, please state the full name and address of the insurance carrier.

   2. The limits of coverage [total and per occurrence] and the amount of any deductibles.

   3. The period covered by the policy, and the specific acts covered for such period. Also, please state whether or not the contract of insurance is an “occurrence” or a “claims made” policy.

   4. Set forth the amount of the premium and indicate what amounts, if any, remain to be paid with respect to the premium.

   5. State whether or not you will, without a motion to produce, attach a copy of the declaration sheet and policy to your answers to these interrogatories.

7. Please state whether or not you observed the Plaintiff sustain any injury at the time of the subject incident? If your answer is anything other than an unqualified “No,” please set forth the following information specifically and in detail for each injury:

   1. The precise cause of the injury and the nature of the injury.

   2. A description of any expressions or cries of pain during or after the incident.

   3. The name, address, title, occupation and relationship to the parties of each person who witnessed the injury.

8. When did you or your agents last conduct a safety inspection of the subject premises prior to the incident? With respect to that inspection, please set forth the following information specifically and in detail:

   1. State whether or not any dangerous conditions were discovered and, if so, describe each such dangerous condition.

   2. Did you ever receive any complaints or notices with respect to any dangerous condition? If so, please describe each complaint and what steps, if any, that were taken in response to the complaint.

   3. Please identify each complaint or notice of a dangerous condition that was called to your attention within a ___ month period preceding the subject incident. And, for each notice and complaint, state the name and address of each person who provided it; also provide a summary of its contents.

9. Are you aware of any procedure, checklist or protocol for periodically inspecting the subject premises? If your answer is anything other than an unqualified “No,” please set forth the following information specifically and in detail:

   1. Describe the procedure, checklist or protocol in detail.

   2. Please set forth the name, address, title, occupation and relationship to the parties of each person responsible for conducting or executing any part of the procedure, checklist or protocol.

   3. Was the preceding procedure, checklist or protocol followed with respect to the applicable period of time preceding the...