Preliminary Sections

• Author: Kevin R. Culhane
• Pages: 1-78

Model Interrogatories

by Judge Kevin R. Culhane

HIGHLIGHTS

Here is your annual update to one of the most comprehensive and usable collections of pre-drafted discovery

questions and checklists. This year’s update adds two new chapters and expands two others:

New Chapter 32 Domestic Violence

Elements of plaintiff’s domestic violence cause of action

Basic information regarding defendant and plaintiff

Acts constituting domestic violence

Relationship between the parties

Defenses

Damages

Investigatory questions

New Chapter 33 Gender-Related Violence

Elements of plaintiff’s cause of action

Basic information regarding defendant and plaintiff

Acts constituting gender-related violence

Defenses

Damages

Investigatory questions

Expanded Chapter 24 Defamation

New. Deposition of Defendant. §2491

New. Deposition of Plaintiff. §2492

Covers libel, slander, affirmative defenses and denials, damages, statements, surveillance, and insurance.

Expanded Chapter 28 Intentional Torts

New. Deposition of Defendant. §28301

New. Deposition of Plaintiff. §28302

Covers basic facts, battery, false imprisonment, intentional infliction of emotional distress, defenses, conversion,

defenses, damages, statements, surveillance, and insurance.

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