Plaintiff's Interrogatories and Request to Admit-Notice of Non-Party Fault

PLAINTIFFS’ INTERROGATORIES AND

REQUEST TO ADMIT DIRECTED TO DEFENDANT

REGARDING NOTICE OF NON-PARTY FAULT

NOW COME Plaintiffs, , by and through their attorneys, , and requests that the following Interrogatories, submitted under MCR 2.309, be answered by Defendants, under oath and that the answers be served upon the undersigned attorney for Plaintiff within twenty eight (28) days.

When used in these Interrogatories, the term “Defendant” or any synonym thereof is intended and shall embrace and include in addition to said Defendant, all agents, servants and employees, representatives, private investigators, or others who are in possession of or who may have obtained information for or on behalf of Defendant.

These Interrogatories are to be regarded as continuing and you are requested to provide, by way of supplementary answers thereof, such additional information as may hereafter be obtained by you or any person on your behalf which will augment or otherwise modify answers now given to these Interrogatories. Such supplemental responses are to be filed and served upon Plaintiffs with twenty eight (28) days after receipt of such information.

INTERROGATORIES

1. With regard to as to whom Defendant filed a Notice of Non-Party Fault, please provide the full name and address of this person/entity.

   ANSWER

2. With regard to as to whom Defendant filed a Notice of Non-Party Fault, please provide each and every piece of tangible or physical evidence that you have to show that this person or entity was negligent in any way in contributing to the incident described in Plaintiffs’ Complaint.

   ANSWER

3. With regard to as to whom Defendant filed a Notice of Non-Party Fault, please identify each and every person who will testify regarding the negligence as indicated in Defendant’s Notice of Non-Party Fault. Please provide their full name, address and telephone number.

   ANSWER

4. With regard to as to whom Defendant filed a Notice of Non-Party Fault, please state whether this Defendant is in possession of any statements, photographs, diagrams or other evidence supporting the Notice of Non-Party Fault?

   ANSWER

5. If the...