DEFENDANT'S APPROVED AUTO ACCIDENT INTERROGATORIES TO PLAINTIFF IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS STATE OF MISSOURI _________________________, Plaintiff, vs. _________________________, Defendant. ) ) ) ) ) ) ) ) ) Cause No. _________ Division No. ________ DEFENDANT'S INTERROGATORIES DIRECTED TO PLAINTIFF Comes now defendant, and in accordance with the Missouri Rules of Civil Procedure, exhibits the following interrogatories, to be answered by plaintiff under oath within thirty (30) days. 1. Please state: (a) (b) (c) ANSWER: The name and address of the person or persons answering these interrogatories; His/her relationship to plaintiff; and His/her position of employment. 2. BACKGROUND INFORMATION Please state: (a) (b) (c) (d) (e) (f) (g) (h) (i) Plaintiff's full name; Name of plaintiff's spouse and date of marriage; Plaintiff's maiden name, if applicable; Plaintiff's age and date of birth; Plaintiff's social security number; Plaintiff's present address; Any other addresses at which plaintiff has lived during the past five years; Plaintiff's present employer's name and position of employment; Previous employers' names for the past five (5) years and the dates of your employment there. American LegalNet, Inc. www.FormsWorkFlow.com DEFENDANT'S APPROVED AUTO ACCIDENT INTERROGATORIES TO PLAINTIFF (j) Whether or not at the time of the collision referred to in plaintiff's petition, this defendant was performing any business task or job at the request of or on behalf of defendant's employer, and if so, please state the nature of the task or job being performed and the name of the employer. ANSWER: 3. STATEMENTS Are you aware of any statement made by defendant (or its employees) regarding the occurrence mentioned in the petition, whether oral, written or recorded in any way, including, but not limited to, a stenographic, mechanical, electrical, audio, video, motion picture, photograph, or other recording, or transcription thereof, and, if so, state the following: (a) (b) (c) (d) (e) (f) (g) Date, place, and time taken; Name and addresses of all persons connected with taking it; Names and addresses of all persons present at the time it was taken; Whether the statement was oral, written, shorthand, recorded, taped, etc.; Was it signed? Names and addresses of the persons or organizations under whose direction and upon whose behalf it was taken or made; Please attach an exact copy of the original of the statement, interview, report, film, or tape to your answers to these interrogatories; if oral, please state verbatim the contents thereof. ANSWER: 2 American LegalNet, Inc. www.FormsWorkFlow.com DEFENDANT'S APPROVED AUTO ACCIDENT INTERROGATORIES TO PLAINTIFF 4. PHOTOGRAPHS, ETC. State whether there exist photographs, videotapes, or movies with respect to the automobiles or scene of the occurrence mentioned in the petition. If so, state the following: (a) (b) (c) (d) Describe each photograph, video or movie; State the date each was taken; State the name and address of the person taking each such photo, video, or movie; State the name, address, employer, insurer and job title of the person presently having control or custody of each photograph, video or movie. ANSWER: 5. EXPERTS List and identify: (a) Each person this plaintiff expects to call as an expert witness at trial, stating for each such expert: Name; Address; Occupation; Place of Employment; Qualifications to give an opinion (if such information is available on an expert's curriculum vitae you may attach a copy thereof in lieu of answering this interrogatory subpart); With respect to each expert listed, please state the subject matter on which the expert is expected to testify and the expert's hourly deposition fee. Identify each non-retained expert witness, including a party, who the plaintiff expects to call at trial who may provide expert witness (i) (ii) (iii) (iv) (v) (b) (c) 3 American LegalNet, Inc. www.FormsWorkFlow.com DEFENDANT'S APPROVED AUTO ACCIDENT INTERROGATORIES TO PLAINTIFF opinion testimony by providing the expert's name, address and field of expertise. State also any opinions the expert will testify to at trial. ANSWER: 6. WITNESSES State the names and addresses of every person known by plaintiff, plaintiff's representatives or plaintiff's attorney to have witnessed the occurrence mentioned in the petition, or who was present at the scene within sixty (60) minutes of the occurrence. Designate which of such people actually claim to have witnessed the occurrence. ANSWER: 7. CRIMINAL RECORD State whether plaintiff has ever pleaded guilty to or has ever been convicted of a felony or misdemeanor (State or Federal), and if your answer is in the affirmative, please state: (a) (b) (c) ANSWER: The date of any such plea or conviction; The state and county where said plea or conviction occurred; The offense for which you pled guilty or were convicted. 4 American LegalNet, Inc. www.FormsWorkFlow.com DEFENDANT'S APPROVED AUTO ACCIDENT INTERROGATORIES TO PLAINTIFF 8. DESTINATION, ETC. State where plaintiff was coming from and the place of his/her destination at the time of the accident in question. ANSWER: 9. AUTO OWNERSHIP AND PROPERTY DAMAGE (a) (b) State the name and address of any and all registered or equitable owners of the vehicle being operated by plaintiff at the time of the occurrence in question. State whether repair estimates were obtained or the vehicle was repaired, and if so, please state the amounts of any estimates and/or repair costs and the names and addresses of each person or company who prepared an estimate or repaired the vehicle. ANSWER: 10. VIOLATIONS State whether plaintiff or his/her representatives was/were convicted of or pled guilty to any violation arising out of the collision in question, and if so, state the charges for which plaintiff or his/her representatives was/were convicted or pled guilty, the name and address of the court where same occurred, the date of final disposition, and the cause number for plea or conviction. ANSWER: 5 American LegalNet, Inc. www.FormsWorkFlow.com DEFENDANT'S APPROVED AUTO ACCIDENT INTERROGATORIES TO PLAINTIFF 11. ALCOHOL, ETC. State whether the plaintiff consumed alcoholic beverages, medication, or drugs within a ten hour period prior to the collision in question, and if so, state the names and addresses of the places where said alcoholic beverages, medication, or drugs were consumed and describe the quantity and type of drinks, medication or drug