Plaintiff's Proposed Pattern Interrogatories and Request for Production

CAUSE NO. _______

§ THE COUNTY COURT

PLAINTIFF §

§ AT LAW NO. ___

§

VS. §

§

DEFENDANT § [COUNTY, STATE]

PLAINTIFF’S PROPOSED PATTERN

INTERROGATORIES AND REQUEST FOR PRODUCTION

COMES NOW, Plaintiff in the above styled and numbered cause, pursuant to the Texas Rules of Civil Procedure, submits the following proposed pattern interrogatories and request for production for consideration by the court:

I.

INTERROGATORIES

INTERROGATORY NO. 1:

Describe Plaintiff’s employment history. As part of your answer, state the following: dates of employment, dates of any layoffs and recalls and reasons for each layoff and recall, dates of termination of employment and reasons for each termination of employment, wage rates during all periods of employment, gross compensation earned during all periods of employment, fringe benefits during all periods of employment, job titles and dates employed in each position, a description of job duties for each position of employment held and identify Plaintiff’s supervisor(s) for each position held.

ANSWER :

INTERROGATORY NO. 2:

State each amount of money paid by Defendant or its agents or insurers in connection with Plaintiff’s workers’ compensation claim or claims and identify the payee for each amount paid.

ANSWER:

INTERROGATORY NO. 3:

State with particularity the factual basis for any termination, reassignment, disciplinary action, change in compensation, change of job duties, change of work hours and/or any other employment action that occurred following Plaintiff’s injury and/or workers’ compensation claim. As part of your answer, state the job description or position of each person involved, their job duties and what actions they took or decisions they made that relate to the Plaintiff.

ANSWER :

INTERROGATORY NO. 4:

If you contend that Plaintiff’s injury was not work related, was a pre-existing injury, that Plaintiff exaggerated or is/was in any way untruthful about the cause, nature or extent of the injury, or that Plaintiff was in any way untruthful about his/her ability to perform any job duties or tasks as a result of the injury, then state the basis for your contentions and identify all facts, documents, photographs, recordings, video, testimony and/or any other evidence you claim supports your contentions.

ANSWER :

INTERROGATORY NO. 5 :

Identify each and every person involved in the handling of Plaintiff’s work related injury and/or workers’ compensation claim. As part of your answer, state the job description or position of each person involved, their job duties and what actions they took that relate to the Plaintiff. This request includes, but is not limited to, all persons who were involved in any of the following that related to Plaintiff: documentation of Plaintiff’s injury and/or accident, medical treatment or evaluation, claims handling, reporting to any governmental agency, and communication with any of Plaintiff’s healthcare providers.

ANSWER :

INTERROGATORY NO. 6 :

Identify each and every allegation in Plaintiff’s Petition filed in this lawsuit which you assert is false or inaccurate, and detail specifically all facts, documents, photographs, testimony and/or any other evidence you claim proves these allegations are false or inaccurate, and identify the true or accurate facts that demonstrate the falsity or inaccuracy of such allegations.

ANSWER :

INTERROGATORY NO. 7:

If you, your attorneys, or your associates have any knowledge, either directly or indirectly, of any admission against interest or any statement or admission of any kind made by any party to this lawsuit, including but not limited to, Defendant (including any agent or employee), Plaintiff or anyone acting by or on the Plaintiff’s behalf and/or any third party who had a contractual relationship with any defendant relevant to Plaintiff’s claims, Plaintiff’s employment with you, Plaintiff’s injury and/or...