Interrogatories - Workplace Liability

General Unsafe Work Area

[A] Questions to Defending Employer

1. State your full name, address, occupation, title, and relationship to the defendant company ___________________; also, please provide the full name, address, occupation, title, and relationship to Defendant of each individual who assisted the answering of these interrogatories.

2. With respect to the address known as:

   ___________________________________________________________________

   ___________________________________________________________________,

   please identify (by name, address, title, and occupation) each of the following persons or entities:

   1. The current owner or owners of the property.

   2. Each current lessee of the property.

   3. Each owner of the property on ____________________ (the date of the subject incident or accident).

   4. Each person or entity who exercised dominion, control or supervision of the property on ____________________ (the date of the subject incident or accident).

   5. Each person or entity who exercised dominion, control or supervision over any individual, worker, employee or laborer at the property on ____________________ (the date of the subject incident or accident).

3. Please state whether or not the Plaintiff was working on the premises located at ________________________________________________________________ on the date upon which the subject incident (or accident) occurred. If your answer is anything other than an unqualified “No,” then please set forth the name, address, title (or entity), and Employer Identification Number of each and every company, business concern or business entity that supervised, hired, directed, managed or employed the Plaintiff for any work at the subject location.

4. For each business concern or business entity that supervised, hired, directed, managed or employed the Plaintiff for any work at the subject location on the subject date, please state its relationship to the defendant, if any.

5. For each person, business concern and business entity that employed, hired or used the services or labor of the Plaintiff on the date in question, please set forth the following information:

   1. Identify the entity or employer by providing its name, address, Employer Identification Number, and telephone number.

   2. The date upon which employment or work began.

   3. The date upon which employment terminated.

   4. A description of the work that the Plaintiff generally performed on a regular basis.

   5. A specific description of the work that the Plaintiff performed on the date of the subject incident or accident.

   6. The name, address, title and employer of each person who immediately supervised, managed or directed the Plaintiff on the date of the subject incident or accident.

6. State whether or not there was any type of an agreement or contract between Defendant and any other company or entity that involved the services or labor of the Plaintiff. If there was, please provide the following information specifically and in detail for each such agreement:

   1. The date of the agreement and the period or periods of time that were covered by it.

   2. The parties to the agreement, including the names, addresses and relationships to the parties herein of all persons who executed the contract.

   3. The specific terms of the contract.

   4. If the contract is not written, please set forth the names, addresses and relationships to the parties herein of each witness to the agreement.

   5. If the contract is written, please set forth the name, address, title, and relationship to the parties of each person who has custody of a copy of the contract.

   6. If the contract is written, please state whether or not you will, without a notice to produce, attach a copy of the contract to your answers to these interrogatories.

7. With respect to every company and entity that you have mentioned or identified in your answers to the preceding interrogatories, please explain and identify the existence of any of the following relationships among them:

   1. General Contractor

   2. Subcontractor

   3. Independent Contractor

   4. Agent

   5. Principal

   6. Employer

   7. Employee

8. Do you contend that, at the time the Plaintiff sustained the injuries which are the subject of this litigation, that he (or she) was not acting within the course and scope of your employment? If so, please set forth all of the facts, information and evidence within your knowledge or possession to support that contention.¹

9. At any time prior to the date of the subject injury, did the defendant or any of its agents, representatives or employees have or receive any notice of the following condition (describe the defective or dangerous condition):

   ___________________________________________________________________

   ___________________________________________________________________

   ___________________________________________________________________

   If your answer is anything other than an unqualified “No,” then for each and every such notice, please set forth the following information specifically and in detail:

   1. The form of the notice (i.e., written notice, letter, complaint, report, email, etc.).

   2. The date and time that the notice was received.

   3. The name, address, title and relationship to the parties of each person who authored the notice.

   4. The name, address, title and relationship to the parties of each person who delivered the notice.

   5. The name, address, title and relationship to the parties of each person who received the notice.

   6. The name, address, title and relationship to the parties of each person to whom the notice was communicated or delivered following its initial receipt; please set forth the date and time that the notice was communicated and the name, address, title and relationship to the parties of the person who communicated the notice.

   7. The substance of the notice.

   8. If the notice was written, please state whether or not you will, without a notice to produce, attach a copy of it to your answers to these interrogatories.

10. Was any person or entity ever instructed to repair, correct or restore the condition more specifically stated in Interrogatory Number 9 above? If so, then for each such instruction, please set forth the following information specifically and in detail:

    1. The name, address, title and relationship to the parties of the person who delivered the instruction.

    2. The name, address, title and relationship to the parties of the person who received the instruction.

    3. The date and time that the instruction was delivered.

    4. The resulting action, if any.

11. Were any repairs, corrections or restorations ever made with respect to the condition more specifically stated in Interrogatory Number 9 above? If so, then for each repair (both before and after the subject incident or accident), please set forth the following information specifically and in detail:²

    1. The name, address, title and relationship to the parties of the person who ordered the repairs.

    2. The name, address, title and relationship to the parties of the person who made the repairs.

    3. The date of the repair.

    4. A detailed and specific description of the repairs.

    5. An identification of every invoice, work order, report, certification or writing relating to the repairs. This identification should include, but not be limited to, the following:

    i. The title of the writing.

    ii. The name, address and title of both the author and...