Section 33 Witnesses Who Have Observed Plaintiff’s Physical Condition

• Library: Damages 2012

Sometimes a defense attorney canvasses the neighborhood or workplace and finds individuals who claim to have valuable testimony concerning the nature and extent of the plaintiff’s physical activities, either before or after the accident. These individuals sometimes appear at trial as surprise witnesses. To ensure that plaintiff’s counsel knows the identity of all such potential witnesses before trial, the following interrogatory is suggested:

State the names, addresses, present occupations, and places of...