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IT IS HEREBY CERTIFIED that on the ____ day of XX, 20__, a true and correct copy of the foregoing was (  ) Telefaxed (X)Mailed to:  XX



Attorney for Plaintiff

2100 East Hallandale Beach Blvd.

Suite 200

Hallandale Beach, FL 33009










(If answering for another person or entity, answer with respect to that person or entity, unless otherwise stated.)

  1. What is the name and address of the person answering these interrogatories, and, if applicable, the person’s official position or relationship with the party to whom the interrogatories are directed?



  1. Describe in detail how the defendant contends the incident described in the Complaint happened.



  1. Describe in detail each act or omission on the part of the Plaintiff that the defendant contends constituted negligence that was a contributing legal cause of the incident in question.



  1. State the facts upon which you rely for each affirmative defense in your answer.



  1. Does the defendant contend that any personal entity not named as a party in this lawsuit is, or may be, liable in whole or in part for the claims asserted against defendant in this lawsuit?  If so, state the full name and address of each such person or entity, the legal basis for defendant’s contention, the facts or evidence upon which defendant’s contention is based, and whether or not the defendant has notified each such person or entity of its contention.



  1. List the names and addresses for all persons who are believed or known by the defendant, its agents or its attorneys to have any knowledge concerning the occurrence of the incident which is the subject matter of this lawsuit, including eye-witnesses, persons who arrived at the scene of the incident within 30 minutes of its occurrence and persons who have knowledge of any foreign or transitory substance that was on the floor at the time of and/or after the subject incident.



  1. Please state the names and last known business and residence addresses and telephone numbers of all of Defendant’s employees who either witnessed Plaintiff fall or who had any responsibility for insuring that the aisle where plaintiff fell was free of foreign or transitory objects or substances.



  1. State the name, address and telephone number of every person known to the defendant, its agents or its attorneys who has knowledge about or possession, custody, or control of any model, plat, map, drawing, motion picture, videotape or photograph pertaining to any fact or issue involved in this controversy; and describe as to each what item such person has, the name and address of the person who took or prepared it, the date it was taken or prepared.



  1. On the day of the subject incident, did defendant have in the store surveillance video(s) of persons walking around the store where the incident occurred?  If so, please state whether or not there is any videotape of the subject incident, including videotape of the location of the incident shortly prior to and after the incident.  Who is the current custodian of any such videotape and what is that person’s relationship to the defendant?



  1. Did the defendant, through any of its employees, determine that there was a foreign or transitory substance on the floor where the incident occurred?  If the answer to this interrogatory is yes, please state the name(s) and last known residence and business addresses and telephone numbers of any person who saw a foreign or transitory substance on the floor and state the nature and origin of such substance.



  1. Has the defendant heard or does it know about any statement or remark made by the plaintiff concerning any issue in this lawsuit?  If so, state the name and address of each person who heard the remark, and the date, time, place and substance of each statement.



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The pleading above is a sample document related to a specific set of facts and circumstances and should not be used or relied upon for any personal injury matter. This document is being provided for illustrative purposes only. We recommend and urge you to consult with an experienced personal injury lawyer for professional advice as each case is unique.

To Learn About Alan’s Qualifications as a Personal Injury Lawyer, See His About Me Page.