Plaintiff's Interrogatories and Requests to Admit to Defendant re Affirmative Defenses

Plaintiff’s Interrogatories and Requests to Admit to Defendant re: Affirmative Defenses

To: Defendant

c/o ____________________

Attorney for Defendant

You are hereby required to answer under oath the interrogatories set forth below, within 28 days following the date of service hereof, in accordance with [the rules governing discovery in your state, e.g., MCR 2.309].

Instructions:

(a)You must answer each interrogatory separately and fully in writing under oath, unless it is objected to, in which event the reason for the objection must be stated in lieu of the answer.

(b)Information to be disclosed includes that which is in the possession of you, your attorneys, investigators, agents, employees or other representatives of you and your attorney.

(c)Where an individual interrogatory calls for an answer which involves more than one part, each part of the answer should be clearly set out so that it is understandable.

(d)Each interrogatory or subquestion must be repeated immediately before the answer to it. Answers must be signed by the person making them. Objections must be signed by the attorney or unrepresented party making them.

(e)Where the term “you,” “Plaintiff” or “Defendant,” are used, they are meant to include every individual party, and separate answers should be given for each person named as a party.

(f)An evasive or incomplete answer is deemed to be a failure to answer under [the rules governing discovery in your state, e.g., MCR 2.313].

(g)You are under a continuing duty to reasonably supplement your answers to these interrogatories with respect to any question directly addressed to the identity and location of persons having knowledge of discoverable matters, and the identity of each person expected to be called as an expert witness at trial, or the subject matter on which he or she is expected to testify. Further, you are under a continuing duty to correct any incorrect response when you later learn that it is incorrect.

1. With the particularity required by [the rules governing discovery in your state, e.g., MCR 2.111], state and separately identify each defense, affirmative or otherwise, that Defendant, will assert or contemplates asserting as of the close of discovery, which is for the purpose of opposing or defeating the liability claims identified in Plaintiffs’ complaint.

   ANSWER

2. In reference to each defense disclosed by Defendants, in answer to question #1 above, and with the particularity required by [the rules...