Plaintiff's Interrogatories and Request to Produce Directed to Defendant Insurance Company

Plaintiff’s Interrogatories and Request to Produce Directed to Defendant Insurance Company

NOW COMES Plaintiff, __________, by and through counsel, ____________, and requests that the following Interrogatories, submitted under MCR 2.309, be answered by Defendant, under oath and that the answers be served upon the undersigned attorney for Plaintiff within twenty eight (28) days.

1. Please set forth the name, address, and job title or capacity of the person answering these interrogatories.

   ANSWER

2. Please state the name, current business and residence address and job title of all persons who assisted in the preparation of these answers.

   ANSWER

3. Has the defendant, at any time, received proof of the fact of loss sustained by plaintiff? If so, for each proof received, please state:

   1. The nature or type of proof received;

   2. When received;

   3. Who in the defendant’s employ received it;

   4. From whom this information was received; and

   5. Will you, without a motion to produce, attach a copy of each item or document referred to above, and if not, why not?

   ANSWER

4. Is it the Defendant’s contention that the Plaintiff’s claim is excluded under the aforesaid policy of insurance? If so, please attach a copy of the exclusion as it appears in the policy of insurance.

   ANSWER

5. Do you have any grounds for contending that Plaintiff is not entitled to uninsured benefits? If so, for each additional ground, please state:

   1. Its substance;

   2. The name, address, telephone number, and job title of each person who has knowledge of such reasons;

   3. The facts known by each person listed in your response to the preceding subsection; and

   4. Identify each record made to support such contention and produce a copy of each record.

   ANSWER

6. Please set forth the name, address, and job title of each person Defendant will have testify whether by deposition or at the trial.

   ANSWER

7. Please set forth the name and address of any and all persons known to yourself or your attorney that may have any knowledge whatsoever of the facts and circumstances related in any way to this matter.

   ANSWER

8. In the event the preceding interrogatory is answered in the affirmative, please state:

   1. The names and addresses of each party who gave a statement;

   2. The name and address of the person who took the statement;

   3. Whether or not said statement was written or oral;

   4. Whether or not the witness was given a copy of the statement; and

   5. Please produce a copy of each statement.

   ANSWER

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