DISTRODUCT FOR THE CIRECT AT MEMPHIS

IN THE CIRCUIT COURT OF TENNESSEE
FOR THE THIRTIETH JUDICIAL DISTRICT AT MEMPHIS

LATOYA DOTSON and DERRICK DOTSON, SR., Individually and as legal guardians of minors, JAMES WILLIAMS and DERRICK DOTSON, JR.,

Plaintiff(s),

vs.

NAHTAN TAT, DOUGLAS TAT, AND JESSICA TAT

Defendant(s).

Docket No. CT-001833-14
DIV II

DEFENDANTS’ FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO PLAINTIFFS

TO:
Nathan Tat, Douglass Tat, AND Jessica Tat c/o Christopher Sobczak, (25704)
Attorney for Defendant, Nathan Tat
4515 Poplar Avenue, Suite 329
Memphis, TN 38117

Defendant submits the following Interrogatories pursuant to the Tennessee Rules of Civil Procedure, to
be answered fully and in writing, and under oath, within the time prescribed by law. Defendant also submits the following Requests for Production of Documents pursuant to the Tennessee Rules of Civil Procedure.
INTERROGATORIES
1. State your full name, date and place of birth, your Social Security Number, the street address of your current residence and the length of time you have resided there.
ANSWER: LaToya Melton Dotson Clarksdale, MS – 09/12/1978 427-59-1379 1638 Beaver Trail Drive Cordova, TN 38016- 10years

2. If you are now or have ever been married, as to each marriage, state the name of your spouse, the date and place of the marriage, the date the marriage was terminated, if terminated by divorce, the date and place of the divorce, the name and the location of the Court, and the present or last known address of any divorced spouse. ANSWER: Derrick Dotson August 12, 2006 Clarksdale, MS. 3. Describe your educational or vocational background, including names and addresses of every school, college, university, or vocational school attended, dates of attendance, and degree obtained, if any. ANSWER: Rust College – 1998-2000 Mississippi Valley State University- 2002-2003 4. State the name and address of each physician or other practitioner of the healing arts who has treated you for the injuries or medical conditions upon which this action is based, and attach copies of any and all medical records in the possession of you or your attorney pertaining to this treatment. ANSWER: Dr. Elizabeth Mann
5. State the name and address of each physician or other practitioner of the healing arts not named in response to Interrogatory Number 4 who has examined you or who has consulted regarding any other injuries or medical conditions within the ten (10) years preceding filing of your Complaint, and briefly describe the injury or condition, the approximate date each physician was consulted, and the treatment received. Attach copies of any medical records in the possession of you or your attorney with respect to any such treatments or consultations.
ANSWER:
6. State the name and address of each hospital or clinic in which you have received treatment, consultation, examination or advice for the injuries or medical conditions mentioned in the Complaint or for any injuries you received or diseases or medical conditions from which you suffered at any time within the ten (10) years preceding filing of the Complaint. Attach copies of any medical records in the possession of you or your attorney with respect to any such treatments or consultations. ANSWER: Methodist Le Bonheur Germantown Hospital 7691 Poplar Ave. Germantown, TN 38138

7. Itemize and attach copies of all bills or other relevant documents reflecting the cost and expense of all medical treatment and services rendered and medicine received as a result of the injuries or medical conditions described in the Complaint. As to each item, list the person or firm with whom such expense was paid or incurred, the date or period on or during which it was incurred and the amount. ANSWER:
8.
Have you ever received any money, whether by settlement, trial, insurance payment or otherwise, for any personal injury? If so, as to each, describe the injury, the amount of payment made, the approximate date or dates. Attach copies of any documents in the possession of you or your attorney pertaining to such claims and payments.
ANSWER:
9. Has any physician or other practitioner of the healing arts ever evaluated you for disability or for impairment in connection with any injury or condition? If so, provide the name and address of the physician, the approximate date of the evaluation, and the disability of impairment assigned, if any. Attach copies of any written reports or records of such evaluations in the possession of you or your attorney. ANSWER: 10. Apart from the present civil action, has any other civil action ever been filed on your behalf against anyone? If so, as to each, explain briefly the nature of the action, the county and state in which it was filed, approximately when it was filed, and the name and address of the attorney who represented you or is representing you. ANSWER:
No
11. Have you ever made a claim against any other party or insurance company in connection with the maters out of which this action arises? If so, as to each such claim, state the name of the party or the name of the insurance company and its insured and its policy number or claim number, the amount of money received to date as a result of the claim, and the date and recipient of any release, trust agreement, covenant not to sue, or other agreement discharging or limiting liability which you have executed. Attach copies of any documents pertinent to such claims in the possession of you or your attorney. ANSWER:
12. Please identify any accidents involving motor vehicles in which you have been involve d, excluding the accident which is the subject of this lawsuit, providing: (a) the date and location; (b) the nature of any personal injury sustained; and (3) whether you received any payment related to property damage or personal injury as a result of the accident. ANSWER: 13. Have you ever made any claim for any of the following benefits: workers’ compensation, disability insurance, Social Security Disability, payments under any other government or insurance program or employment benefit program for any injury or disability, or any service-connected disability? If so, as to each such claim, state the nature and extent of the injury, approximately when the claim was made, the address at which you were living when the claim was made, and with what company, firm, governmental agency or person the claim was filed. Attach copies of any documents pertinent to any such claim in the possession of you or your attorney. ANSWER:
14. List chronologically all employments you have had in the past ten (10) years prior to filing this Complaint and up to the present, including name and address of employer, name of supervisor, position held, dates the employment began and ended, and reason for termination of the employment.

ANSWER: The Life Church of Memphis 1806 N. Germantown Pkwy. Cordova, TN 2006-2008 Teacher/Asst. & Director- Resigned Aimee Farmer- Director Baptist Memorial Hospital 6019 Walnut Grove Memphis, TN 2008-2013

Crossroadss Hospice
Memphis, TN
2013-2014

15. Since the happening of the matters mentioned in the Complaint, have you applied for employment anywhere? If so, state the name and address of each person or firm to whom you have applied for employment. ANSWER: Yes, ECS Federal 225 Humphrey Blvd. Memphis, TN 38120 16. State all facts supporting any claim that you lost any pay or that you are entitled to any compensation for loss of earning capacity, including how much and for what period of time, and attach any documents pertinent to this claim. ANSWER: 17. State the gross amount of your earnings from all employments and attach copies of your federal income tax returns, W-2 Forms, and 1099 Forms of the five (5) previous calendar years. ANSWER: 18. Describe where you had been and what you had been doing for twenty-four (24) hours preceding the accident in this matter, where you were going at the time of the accident, the purpose of such trip and your expected time of arrival there. ANSWER: I was headed home to my family and was expected there by 5:00p.m. 19. Provide a narrative statement of how, when, where and why the accident for which you are making this claim occurred. ANSWER: The motorist was not paying attention and driving extremely fast.
20. State whether you consumed any intoxicating beverage within twelve (12) hours prior to the incident and if so, specify: The type of beverage or beverages; the quantity of each; the time and place each beverage was consumed; and the identity and location of each person known to you who was present when each beverage was consumed.
ANSWER: None 21. List all person with whom you were with within twelve (12) hours prior to the accident, giving their street address and phone number. ANSWER: James Williams and Derrick Dotson 22. List all persons, entities, or things which you believe contributed to cause this accident and state all facts supporting your belief as to each. ANSWER: Nathan Tat 23. State the name and address of each person who (a) was, or was reported to be, an eyewitness to the accident; (b) was at or near the accident scene shortly before or after the accident; (c) has, or may have, knowledge concerning the identity of other witnesses; (d) made or has possession of any photographs of the accident scene, or of any person (including yourself) allegedly injured in the accident; (e) heard any witness or any party make any statement concerning the accident or concerning the facts and circumstances surrounding it; (f) has, or may have, knowledge concerning the facts and circumstances surrounding the accident or your injuries, illnesses or conditions before and after the accident, but whose name has not been provided in answers to any of the questions above. ANSWER: James Williams and Derrick Dotson. 24. State the name and address of each person who reportedly heard or claims to know that any Defendant or representative thereof in this action made any statement, declaration or admission as to liability, responsibility or fault with regard to the accident out of which this action arises.y ANSWER: 25. Please state the names and addresses of all persons, whether or not you intend to call them as witnesses at trial, including Plaintiff, who have knowledge of facts pertaining to the allegations of Plaintiff’s Complaint, and provide a general summary of the facts of which you understand each such person is knowledgeable. ANSWER: James Williams and Derrick Dotson
26. Please state the name, present employer and address of all persons who Plaintiff intends to call as expert witnesses at trial or has consulted with Plaintiff and with respect to each such witness; (a) State the subject matter on which the expert witness is expected to testify; (b) State the substance of the facts and opinions to which the expert witness is expected to testify; (c) State a summary of the grounds of each opinion.
ANSWER:
27. Itemize and explain in detail any claim you made in this action for financial loss or damage which has not been explained in answer to questions above. ANSWER: 28. Fully describe each and every way in which you have been adversely affected by this accident, including but not limited to pain and suffering and the parts of your body affected thereby, loss of enjoyment of life, permanent injury, disfigurement or impairment, loss of mental faculties or capacity, impairment of earning capacity, and modification or cessation of activities. ANSWER:
29. Have you ever been charged with, convicted of, or plead guilty to a crime? As to each instance, state the date of the offense, the nature of the offense, the county and state where the offense occurred and the ultimate disposition of the matter. ANSWER: No
REQUESTS FOR PRODUCTION OF DOCUMENTS

1. Copies of all medical bills alleged to have been incurred for treatment of injuries sustained in this accident.
RESPONSE: 2. Copies of all medical records generated by health care providers as a result of diagnoses, testing, and/or treatment of injuries alleged to have been sustained in this accident.
RESPONSE:
3. Copies of all medical records generated by health care providers as a result of diagnoses, testing, and/or treatment of any injuries, illnesses, or other medical condition, regardless of cause, in the past ten (10) years.
RESPONSE:
4. Copies of all documents referencing or evidencing any settlement, judgment, insurance payment or other payment you have received for any personal injury.
RESPONSE:
5. Copies of any medical and/or vocational evaluations of you which have ever been made for any reason.
RESPONSE:
6. Copies of pleadings from any other civil action to which you have ever been a party.
RESPONSE:
7. Copies of all documents relating to any claim you have made against or payment you have received from any third-party or insurance company in connection with injuries or damages from this accident.
RESPONSE:
8. Copies of all documents from any present or past employer which are relevant to your past or present physical ability to work.
RESPONSE:
9. Copies of your federal income tax returns and W-2 forms or 1099s for the five (5) previous calendar years. In addition , please execute the attached authorization for obtaining tax records.
RESPONSE:
10. Copies of any reports from experts pertaining to this accident or the injuries, damages or disability allegedly incurred as a result thereof.
RESPONSE:
11. Copies of all other documents examined or consulted by you in order to answer any Interrogatory.
RESPONSE:
12. Copies of all photographs, videotapes, drawings, reports, diagrams, or sketches of the accident scene or Plaintiff’s injuries related to this accident.
RESPONSE:
13. Please sign the attached medical and employment authorizations to obtain copies of medical records.
RESPONSE:
Respectfully submitted,

_____________________________________
Christopher Sobczak, (25704)
Attorney for Defendants
Grove Park Center
4515 Poplar Avenue, Suite 329
Memphis, TN 38117
901-766-8120

CERTIFICATE OF SERVICE

I, Christopher Sobczak, do hereby certify that an exact and true copy of the foregoing document was forwarded to attorney Mr. Daryl Gray, Gray Law Group, PLLC, 212 Adams Avenue, Memphis, TN 38103 via postage pre-paid U.S. mail on this the ______ day of October, 2014.

Christopher Sobczak

OATH

STATE OF TENNESSEE

COUNTY OF _______________

I, Latoya Dotson, after first being duly sworn, according to law, hereby make oath that I have read and understand the foregoing Answers to Interrogatories and that they are true and correct to the best of my knowledge, information and belief.

_____________________________________
Latoya Dotson

Sworn to and subscribed before me this ____ day of ___________, 2014.

______________________________________ Notary Public

My commission expires: _______________.

AUTHORIZATION FOR RELEASE OF EMPLOYMENT RECORDS
AND INFORMATION

I, Latoya Dotson, do hereby authorize any employer, including any agent or employee thereof, who has employed me in any capacity at any time, to furnish to any representative of the law firm of Law Office of Paul L. Burson and to permit such representative to examine and photocopy, or receive upon request, any and all information, records, or documents of any kind which may be requested regarding my employment with such employer, including but not limited to my personnel records, employment application, performance evaluations, attendance records, and payroll reports. A copy of this document has the same effect as and may be used in lieu of the original.

________________________________________ Latoya Dotson

SSN: ____________________________________

DATE: __________________________________

AUTHORIZATION FOR RELEASE OF PROTECTED HEALTH INFORMATION

I, Latoya Dotson, hereby authorize the use or disclosure of protected health information about me as described below.

I authorize you to release to Christopher Sobczak or other representatives of the Law Office of Paul L. Burson, any and all records and documents of any kind or description, regardless of the original source or location, relating in any way to the incident of , including, but not limited to, copies of all medical records, MRI reports, test results, etc, physical therapy notes, office notes, x-ray films, lab results, billing statements, and other miscellaneous-type information.

I authorize the release of this information to Law Office of Paul L. Burson for their use in litigation in which the issue of my medical condition and/or history has been raised.

I understand that the information used or disclosed may be subject to re-disclosure by the person(s) or class of person(s) receiving it, and no longer protected by the federal privacy regulations.

I understand that I may revoke this authorization by notifying the designated Privacy Officer of the entity to which this authorization is directed in writing if I desire to revoke it. However, I understand that if I revoke this authorization, it will not have any effect on actions taken by that entity in reliance on it before I revoked it.

I understand that I am not required to sign this authorization. The above-named health care provider will not condition treatment, payment, enrollment or eligibility for benefits on whether I provide this authorization.

A copy of this authorization shall have the same effect as the original, and shall be valid for one year from the date of execution.

_____________________________________
Printed Name of Patient or Representative
_____________________________________
Date of Birth

_____________________________________
Signature of Patient or Representative

_____________________________________
Social Security Number

_____________________________________
Date of Execution

REQUEST FOR SOCIAL SECURITY EARNINGS INFORMATION

1. From whose record do you need the earnings information?

Print the Name, Social Security Number (SSN), and date of birth below. Social Security Name _____________________________________ Number__________________________________________

Other Name(s) Used Date of Birth (Include Maiden Name) _______________________ (Mo/Day/Yr) _____________________________________
_________________________________________________________________________________________________________________
2. What kind of information do you need? □ Detailed Earnings Information For the period(s)/year(s):_____________________________________ (If you check this block, tell us below why you need this information.) ________________________________________________________________________ ________________________________________________________________________ □ Certified Total Earnings For Each Year. For the year(s): _________________________________ (Check this box only if you want the information certified. Otherwise, call 1-800-772-1213 to request Form SSA-7004, Request for Earnings and Benefit Estimate Statement)
_________________________________________________________________________________________________________________
3. If you owe us a fee for this detailed earnings information, enter the amount due using the chart on page 3…………………………………………………………... A. $_____________________ Do you want us to certify the information? □ Yes □ No

If yes, enter $15.00…………………………………………………........ B. $_____________________

ADD the amounts on lines A and B, and Enter the TOTAL amount………………………………………………………….. C. $_____________________

You can pay by CREDIT CARD by completing and returning the form on page 4, or
Send your CHECK or MONEY ORDER for the amount on line C with the request
And make check or money order payable to “Social Security Administration”
DO NOT SEND CASH.
_________________________________________________________________________________________________________________
4. I am the individual to whom the record pertains (or a person who is authorized to sign on behalf of that individual). I understand that any false representation to knowingly and willfully obtain information from Social Security records is punishable by a fine of not more than $5,000 or one year in prison.

SIGN your name here (Do not print) >______________________________________________________ Date _____________________

Daytime Phone Number _________ ____________________ (Area Code) (Telephone Number)
_________________________________________________________________________________________________________________
5. Tell us where you want the information sent. (Please print)

Name _____________________________________________ Address __________________________________________________

City, State & Zip Code ___________________________________________________________
_________________________________________________________________________________________________________________
6. Mail Completed Form(s) To: Exception: If using private contractor (e.g., FedEx) to mail form(s) use:

Social Security Administration Social Security Administration Division of Earnings Record Operations Division of Earnings Record Operations P.O. Box 33003 300 N. Greene Street Baltimore Maryland 21290-3003 Baltimore Maryland 21290-0300
Form SSA-7050-F4 (7-2001) EF (05-2002)