FIRST SET OF INTERROGATORIES TO DEFENDANT ANHEUSER-BUSCH
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
JUSTIN WILLIAM KING, ) )
Plaintiff. ) ) Civil Action No. 11-CIV-012345 )
v. ) )
ANHEUSER-BUSCH COMPANIES, INC. ) Judge Julie James )
Defendant. )
____________________________________)
FIRST SET OF INTERROGATORIES TO DEFENDANT ANHEUSER-BUSCH
To: Defendant Anheuser-Busch and its attorney, John Smith, 234 Main Street, Chicago, IL 60601
PLEASE TAKE NOTICE that plaintiff Justin William King demands answers to the following interrogatories, under oath, pursuant to Rule 33 of the Federal Rules of Civil Procedure.
1. Please describe the cargo load that was on the trailer on the day of the accident, how many stops and in what cities. And what was left on the truck when the accident occurred. Who was in charge of securing the cargo that was on the trailer?
2. What maintenance, if any, was performed on the truck involved in the accident in the past six months prior to the accident?
a. Who performed the maintenance on the truck?
b. What were the faults found?
c. If there were any repairs needed who performed the repairs?
d. If there were any parts that needed to be replaced, which ones were replaced?
3. If you have any expert witnesses please state their names and also their specialties. Also, please state the subject matter on which the expert is expected to testify about.
4. Please state whether your company had performed a drug and alcohol test on your driver, Frank Cuellar, on the day on the accident. If so, what are the results? Have you ever performed a drug test on the driver Frank Cuellar? If so, what where those results?
5. On the truck that was being drove on the day off the accident, are there any devices that may have recorded the accident? Is there a GPS or similar device? If so could you please describe about any data that was downloaded from the vehicle on the day of the accident?
Dated:
FOR THE NORTHERN DISTRICT OF ILLINOIS
JUSTIN WILLIAM KING, ) )
Plaintiff. ) ) Civil Action No. 11-CIV-012345 )
v. ) )
ANHEUSER-BUSCH COMPANIES, INC. ) Judge Julie James )
Defendant. )
____________________________________)
FIRST SET OF INTERROGATORIES TO DEFENDANT ANHEUSER-BUSCH
To: Defendant Anheuser-Busch and its attorney, John Smith, 234 Main Street, Chicago, IL 60601
PLEASE TAKE NOTICE that plaintiff Justin William King demands answers to the following interrogatories, under oath, pursuant to Rule 33 of the Federal Rules of Civil Procedure.
1. Please describe the cargo load that was on the trailer on the day of the accident, how many stops and in what cities. And what was left on the truck when the accident occurred. Who was in charge of securing the cargo that was on the trailer?
2. What maintenance, if any, was performed on the truck involved in the accident in the past six months prior to the accident?
a. Who performed the maintenance on the truck?
b. What were the faults found?
c. If there were any repairs needed who performed the repairs?
d. If there were any parts that needed to be replaced, which ones were replaced?
3. If you have any expert witnesses please state their names and also their specialties. Also, please state the subject matter on which the expert is expected to testify about.
4. Please state whether your company had performed a drug and alcohol test on your driver, Frank Cuellar, on the day on the accident. If so, what are the results? Have you ever performed a drug test on the driver Frank Cuellar? If so, what where those results?
5. On the truck that was being drove on the day off the accident, are there any devices that may have recorded the accident? Is there a GPS or similar device? If so could you please describe about any data that was downloaded from the vehicle on the day of the accident?
Dated: