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Justin King- Plaintiff
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v.
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Anheuser-Busch, INC- Defendant
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PLAINTIFF’S INTERROGATORIES TO DEFENDANT
TO: Defendant Truck Driver
BY: Plaintiff
Plaintiff, by and through his attorney, requests that the defendant answer the following Interrogatories fully, under oath and in accordance with the Federal Rules of Criminal Procedure (FRCP), title V, Rule 33.
Interrogatory 1- Were you cautious and thorough when you locked he door on the truck, making sure your cargo was properly secure and was not going to fall out before leaving your stating point of your route? If your answer is yes, was there anyone that witnessed you checking the lock like a passenger, inspector, manager, or by-stander? (Please list full names if any.) …show more content…
Interrogatory 2- If you were on the clock and under the employment of Anheuser-Busch at the time of the accident, please state if you were required to file a report within a certain amount of time within the course of the business as a result of the accident.
Please identify your employer in which you filed to, and state what you were doing as per your job description at the time of the accident.
Interrogatory 3- Were you or any passengers under the influence of any alcoholic beverage or drugs, prescription, over the counter, or illegal within six (6)- eight(8) hours prior to the accident, and if the answer is affirmed, please state where they were purchased and consumed and how much was consumed.
Interrogatory 4- What was your scheduled route at the time of the accident? Starting at the place and time of the beginning, the place and time and how long each stop took, the route that was taken (Highway numbers), and the destination and anticipated time of arrival at the ending
destination.
Interrogatory 5- After the accident, did you speak to the Plaintiff, any witnesses, or investigators at the scene where the accident occurred or anytime after the accident? If the answer is yes, please state the conversation in detail as to what was conversed about and to whom.
Respectfully submitted,
AUGUST LAW OFFICE
Amy August
875 Hoytsville, Rd
Hoytsville, UT 84017
(123)456-6789 (office)
Attorney for Plaintiff
IN THE CIRCUIT COURT OF ILLINOIS
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Justin King- Plaintiff
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v.
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Anheuser-Busch, INC- Defendant
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DEFENDANT’S INTERROGATORIES TO PLAINTIFF
TO: Plaintiff Justin King
BY: Defendant
Defendant, by and through his attorney, requests that the plaintiff answer the following Interrogatories fully, under oath and in accordance with the Federal Rules of Criminal Procedure (FRCP), title V, Rule 33.
Interrogatory 1- Were there any statements concerning the accident made to any police officer, investigator, insurance company , or anyone else> If the answer is yes, please indicate the following:
(a) The full names, address and place of employment of the person to whom the statement was made to.
(b) The date the statement was made.
© Was the statement an oral statement or a written statement? If oral, was it recorded or documented in any way?
Interrogatory 2- What were the physical and/or mental injuries you claim were a result of the accident?
Interrogatory 3- Were there any preexisting injuries (physical or mental) before the accident? If the answer is yes, please answer the following:
(a) When did these injuries take place?
(b) Was there any medical treatment involved with these injuries? If yes, please list the names, addresses, and phone numbers of the physicians that treated you.
© Are there unpaid medical bills from these injuries?
(d) Are you on any long term medication for these injuries? If yes, please provide a list of medications.
Interrogatory 4- Please state the names and addresses of all doctors, chiropractors, hospitals, therapists and any other health care providers who have treated you and/or helped take care of you for the last ten (10) years prior to the accident.
Interrogatory 5- List all past and present medical or health care expenses you have incurred as a result of the accident.
Respectfully submitted,
LAW OFFICE OF HAILTON AND DOME
Betty Hamilton
Suite 45
Blue Bell Plaza
Salt Lake City, UT 87566
(909) 786-4566 (office)
Attorney for Defendant