PLAINTIFF’S RESPONSE TO DEFENDANT’S INTERROGATORIES
IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA
CASE NUMBER: XX
CVS PHARMACY, INC.,
PLAINTIFF’S RESPONSE TO DEFENDANT’S INTERROGATORIES
Plaintiff, MELISSA THOMPSON, by and through the undersigned counsel, hereby files her answer to Defendant=s, CVS PHARMACY, INC., Interrogatories propounded upon Plaintiff dated XX, 20__.
CERTIFICATE OF SERVICE
IT IS HEREBY CERTIFIED that on this ____ day of XX, 200__, a true and correct copy of the foregoing was mailed to:
LAW OFFICE OF ALAN D. SACKRIN
Attorney for Plaintiff
2100 East Hallandale Beach Blvd.
Hallandale Beach, FL 33009
ALAN D. SACKRIN
PLAINTIFF’S RESPONSE TO INTERROGATORIES
- 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.
- List the names, business addresses, dates of employment, and rates of pay regarding all employment position(s) held and name of direct supervisor regarding all employers, including self-employment, for whom you have worked in the past ten (10) years, and list all jobs you are qualified to perform by education, training or experience.
- If you have ever been involved in an accident of any kind prior to or subsequent to the subject incident (this refers to all kinds of accidents, vehicular, aircraft, slip-and-fall, on-the-job, or otherwise) state when, where and how each accident/incident occurred and the names or identities of other people involved.
- If you were injured in any of the accidents/incidents described in your answer to interrogatory no.3, describe your injuries, state the names and dates of treatment of any hospitals wherein you received treatment for such injuries and state the names of all doctors you saw for each accident, and identify which doctor you saw for each accident.
- If you have ever been involved in any type of occurrence other than an “accident” serious enough to cause personal injury or property damage and which occurred either prior to or subsequent to the subject incident, please describe briefly each such occurrence and your role therein (question refers to assault, mutual combat, or any other non-accident incident).
- Describe all personal injuries you receive in the subject incident or event described in your complaint. (In answering this question, specify the part or parts of your head, neck, back limbs and body which were injured and specify whether each part mentioned was broken, sprained, strained, lacerated, contused or otherwise injured.)
- State the name and address of all hospitals and doctors who have provided medical treatment to you for any reason since and including the subject incident, stating the dates for such treatment, the typed of such treatment, the results of such treatment, and specify the specialty of each doctor and/or the reason you saw him/her.
- If there is any activity in which you are limited or hampered by injuries sustained in the subject incident, describe each such activity and the extent to which you are hampered or limited with respect to each activity listed.
- If you suffered from any disease, sickness or illness of sufficient severity or of consequence to require hospital treatment prior to the subject incident, describe each disease, sickness or illness you suffered (giving the year each occurred) and give the name and address or illness you suffered (giving the year each occurred) and give the name and address of each hospital where you received treatment for such disease, sickness or illness.
- Did you consume any alcoholic beverages or take any drugs or medications within twelve hours before the time of the incident described in the complaint? If so, state the type and amount of alcoholic beverages, drugs, or medication which were consumed, and where you consumed them.
- If you are claiming loss of past earnings, state how much and show how you computed your answer to this interrogatory?
- Please state your total gross from all sources in each of the past ten taxable years, showing all sources of said income. (Give names and addresses of all employers. If self-employed income was earned, describe fully).
- If you are claiming loss of future earnings capacity, state how much and show how you computed your answer to this interrogatory.
- Itemize your expenses or damages incurred as a result of the subject incident by giving: (a) a description of each item claimed: (b) the name of the person, firm or company to who each item was paid or incurred; and (c) the amount of each item in dollars and cents. (In answering this question, list all expenses you are claiming as damages including, but not limited to, ambulance bills, hospital bills, doctors’ bills, nurse’s bills, drugs, medicines and other forms of treatment apparatus and appliances, transportation expense, property damage and other items claimed.)
- Has anything been paid or is anything payable from any third party for the damages listed in your answers to these interrogatories? If so, state the amounts paid or payable, the name and business address of the person or entity who paid or owes said amounts, and which of those third parties have or claim a right of subrogation.
- List the names and addresses of all persons who are believed or known by you, your agents, or your attorneys to have any knowledge concerning any of the issues in this lawsuit; and specify the subject matter about which the witness has knowledge.
- Have you heard or do you know about any statement or remark made by or on behalf of any party to this lawsuit; other than yourself, concerning any issue in this lawsuit? If so, state the name and address of each person who made the statement or statements, the name and address of each person who heard it, and the date, time, place, and substance of each statement.
- State the name and address of every person known to you, your agents, or your attorneys, who has knowledge about, or possession, custody, or control of, any model, plat, map, drawing, motion picture, video tape, 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, and the date it was taken or prepared.
- Do you intend to call any expert witnesses at the trial of this case? If so, state as to each such witness the name and business address of the witness, the witness’s qualifications as an expert, the subject matter upon which the witness is expected to testify, the substance of the facts and opinions to which the witness is expected to testify, and a summary of the grounds for each opinion.
- Have you made an agreement with anyone that would limit that party=s liability to anyone for any of the damages sued upon in this case? If so, state the terms of the agreement and the parties to it.
- Please state if you have ever been a party, either plaintiff or defendant, in a lawsuit other than the present matter, and if so, state whether you were plaintiff or defendant, the nature of the action, and the date and court in which the suit was filed.
- Describe in detail how the injury which is the subject matter of the complaint occurred.
- Describe in detail each act or omission on the part of any party to this lawsuit that you contend constituted negligence that was a contributing legal cause if the subject incident.
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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.
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