First set of interrogatories to defendant

Plaintiff requests that Defendant serve its answers, in writing and under oath, to the undersigned counsel for Plaintiff at Seventh Street, N. For the purpose of these Interrogatories only, Plaintiff has used the definitions set forth below.

First set of interrogatories to defendant

Neinast, acting pro se, and propounds his first set of interrogatories and request for production of documents pursuant to Rules 33 and 34 of the Ohio Rules of Civil Procedure. The Plaintiff asks that the Defendants answer the interrogatories and document requests within twenty-eight 28 days of service, appending the requested documents to those Answers.

Pursuant to Civil Rule 26 ethese interrogatories are continuing so as to require the filing of subsequential answers promptly in the event that Defendants, by or through any of their agents, counsels or other representatives, learn additional facts relevant to any answers not set forth in their answers to these Interrogatories or discover that any information given in an answer or answers is erroneous.

Each interrogatory is to be answered separately and as completely as possible. The fact that investigation is continuing or that discovery is not complete does not excuse First set of interrogatories to defendant to answer each interrogatory as fully as possible.

The omission of any name, fact, or other item of information from an answer shall be deemed a representation that such name, fact, or other item is not known to Defendant, his agents, counsel, or other representatives at the time the answers to these Interrogatories are served upon Plaintiff.

For each and every answer to these Interrogatories: If the answer to any of these Interrogatories was made by referring to or reviewing any documents, identify each and every document referred to or reviewed and the Interrogatory or Interrogatories in connection with which they were used.

As used in these Interrogatories the singular shall be deemed to include the plural, the plural to include the singular, and words in the masculine, feminine, or neuter shall include each of the other genders as necessary to make the Interrogatory inclusive rather than exclusive.

Where an Interrogatory contains a general question or questions, followed by a specific question or questions, the specific question or questions are to be read and interpreted as requesting additional information, not as limiting the general question or questions.

With respect to each Interrogatory, identify each and every document prepared by, or in the possession, custody, or control of you or any of your officers, agents, or employees that relates to or refers to the subject matter of the Interrogatory in question.

Whenever information is requested in one of the following Interrogatories or subparts thereof that you previously furnished in answer to another Interrogatory herein, such information need not be restated. It will be sufficient for you to identify the previous answer containing the information requested.

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Whenever an Interrogatory calls for information that is not available to you in the form requested but which is available in another form or can be obtained at least in part from other data in your possession, so state and either i supply the information requested in the form in which it is available or ii supply the data from which the information requested can be obtained.

If you claim a privilege with respect to information pertaining to any document that you are asked to identify or describe in these Interrogatories, furnish a list signed by counsel giving the following information with respect to each such document: The title of the document; b.

The nature of the document, e. The identity of the sender and the identity of the recipient s of the document; d. A statement of the basis upon which the privilege is claimed and a summary of the subject matter of the document in sufficient detail to permit the Court to rule on the propriety of the claim of privilege; and e.

The paragraph number of the Interrogatory to which the document is responsive or otherwise pertains. Interrogatories calling for numerical or chronological information shall be deemed, to the extent that precise figures or dates are not known, to call for estimates.

In each instance that an estimate is given, identify it as such together with the source of information upon which you base the estimate. In answering these Interrogatories every source of information to which you have access should be consulted, regardless of whether the source is within your immediate possession or control.

Plaintiff's First Set of Interrogatories and Request for Production of Documents

All documents or other information in the possession of experts or consultants should be consulted. It includes the possible direct or tacit agreement of the Board of Trustees.

Please identify any persons by name, address, and Library position who answered or assisted in answering these Interrogatories. Does the Library have an insurance policy covering the Library against the negligent, wanton, or willful acts of its employees that might result in an injury tort action against the Library?

If so, please attach details on the extent of the coverage. Does the Library have a contract with any cleaning service or other company in which that service agrees to defend, indemnify, or insure against any portion of injury lawsuits filed against the Library?

If so, please identify that service and attach relevant portions of that contract.

Plaintiff's First Set Of Interrogatories To Defendant | ATR | Department of Justice

If so, please append a copy of the relevant portion of these insurance policies to your Answers. Please provide details about any lawsuits by patrons against the Library in the past five 5 years. Only include lawsuits in which the patron was injured on Library premises. Please include the court, the case title, the case number, the type of injury, the type of footwear the patron was wearing if knownand whether the patron recovered or not.

Do you contend that any relevant Health Department requires shoes in public buildings? If so, which Health Department? Do you contend that bare feet on a patron are in any way disruptive of the Library environment, or represent a danger to any other patrons?

Has the library issued instructions to personnel including guards on how to deal with barefoot patrons, either verbally or in writing? If verbally, describe those instructions; if in writing, please attach a copy of those instructions. Include the approximate date on which the instructions were issued.

If any of these policies have changed in any material way since January,please also attach the previous relevant policy. Does the Library have a rule to prevent children from sitting or crawling on the floor.

Please provide a simple yes or no answer.Defendant is not in the possession, custody or control of any documents responsive to this request. Produce any documents that support your contention that the account was paid in full.

Response: Defendant is not in the possession, custody or control of any documents responsive to this request. On February 15, , I served the foregoing document described as DEFENDANT LAWRENCE LEVITISAN ’S FIRST SET OF INTERROGATORIES TO PLAINTIFF on the interested party(ies) in this action by placing a true copy thereof enclosed in a sealed.

PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT Pursuant to Fed. R. Civ. P. 33, Plaintiff hereby submits the following Interrogatories to Defendant. Plaintiff requests that Defendant serve its answers, in writing and under oath, to the.

First set of interrogatories to defendant

1 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK [insert individual case information])) MDL NO. ))) PLAINTIFF’S FIRST SET OF INTERROGATORIES. plaintiff's first set of interrogatories to defendant Pursuant to Fed. R. Civ. P. 33, Plaintiff hereby submits the following Interrogatories to Defendant.

Plaintiff requests that Defendant serve its answers, in writing and under oath, to the undersigned counsel for Plaintiff at Seventh Street, N.W., Room , Washington, D.C. , within 30 days of service of these Interrogatories.

You are here Zois, and Miller and Zois, LLC, requests that the Defendant, William Parcells, answer the following Interrogatories fully, under oath, and in accordance with the Maryland Rule of Civil Procedure, Rulesubject to the instructions set forth below: Instructions These Interrogatories are continuing in character so as to require you to file supplementary answers if you obtain further or different information before trial.
Collection of Information Title Country Other Information:
Plaintiff's First Set Of Interrogatories To Defendant | ATR | Department of Justice Title Country Other Information:
Interrogatories in a Car Accident Case | Personal Injury Samples Neinast, acting pro se, and propounds his first set of interrogatories and request for production of documents pursuant to Rules 33 and 34 of the Ohio Rules of Civil Procedure.
How do we use this information? Plaintiff requests that Defendant serve its answers, in writing and under oath, to the undersigned counsel for Plaintiff at Seventh Street, N. For the purpose of these Interrogatories only, Plaintiff has used the definitions set forth below.

Standard First Set of Interrogatories in a Car Accident Case Below is a example of interrogatories in a car accident case to serve on the defendant driver/insurance company. We sent out a second and third set of interrogatories in this case.5/5.

Legal Forms | First Set of Interrogatories to Defendant | Bill Daniels - JDSupra