Plaintiff's Witness Interrogatories Directed to Defendant

Plaintiff’s Witness Interrogatories Directed To Defendant

NOW COMES the Plaintiff, _____________, by and through attorneys, _____________________, and hereby requests that Defendant, ______________, answer the following Interrogatories, submitted under [Rule], and that the Interrogatories be answered under oath by you, your agents, representatives, or attorney, who is competent to testify on your behalf concerning the facts about which inquiry is hereby made; and that the answers be served on the undersigned Attorney for Plaintiff within twenty- eight (28) days from the date these Interrogatories are served upon you.

These Interrogatories are deemed continuing and you are requested to provide, by way of supplementary answers, 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. These Interrogatories refer to the date of accident in question as stated in Plaintiff’s Complaint.

INTERROGATORIES

1. Please state a short and concise summary of the testimony you expect from all of the non-expert witnesses listed on your Witness List.

   ANSWER

2. Have you or anyone acting on your behalf taken any statements from the individuals listed on your Witness List referenced above? If so, please state:

   1. The name and address of each person from whom a statement was taken;

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

   3. The nature of each such statement (written, oral, etc.);

   4. The date each such statement was taken;

   5. The name and address of the person currently having custody of each such statement;

   6. If you will voluntarily make a copy of each such statement available to us without the necessity of a Motion to Produce.

   ANSWER

3. For each expert witness listed on your Witness List, please state:

   1. The address of each such expert;

   2. The date of each consultation you had with each expert;

   3. Whether any written material was provided to each expert and, if so, please identify said written material and its present location;

   4. Please state the subject matter on which each expert is expected to testify;

   5. Please state the substance of the facts and opinions to which each expert is expected to testify;

   6. Please state a summary of the grounds for each opinion held by each expert and its qualifications to state each such opinion;

   7. Please state each expert’s qualifications to state each opinion;

   8. Please identify any written material...