Missouri > Local Circuit Courts > 22nd Circuit (St. Louis City) > Civil
Plaintiffs Approved Auto Accident Interrogatories To Defendant - Missouri
| Plaintiffs Approved Auto Accident Interrogatories To Defendant Form. This is a Missouri form and can be used in Civil 22nd Circuit (St. Louis City) Local Circuit Courts . |
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PLAINTIFFS APPROVED AUTO ACCIDENT INTERROGATORIES TO DEFENDANT IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS STATE OF MISSOURI_________________, ) ) Plaintiff, ) ) Cause No. __________ vs. ) ) Division No. _______________________, ) ) Defendant. ) PLAINTIFFS INTERROGATORIES DIRECTED TO DEFENDANT Comes now plaintiff and, in accordance with the Missouri Rules of CivilProcedure, exhibits the following interrogatories, to be answered by defendantunder oath within thirty (30) days. 1. Please state: (a) The name and address of the person or persons answering these interrogatories: (b) His/her relationship to defendant; and (c) His/her position of employment. ANSWER: 2. BACKGROUND INFORMATION Please state: (a) Defendants full name; (b) Name of defendants spouse; (c) Defendants maiden name, if applicable; (d) Defendants age and date of birth; (e) Defendants social security number; (f) Defendants present address; (g) Any other addresses at which defendant has lived during the past five years; (h) Defendants present employers name and position of employment; (i) Previous employers names for the past five (5) years and the dates of employment there; <<<<<<<<<********>>>>>>>>>>>>> 2 PLAINTIFFS APPROVED AUTO ACCIDENT INTERROGATORIES TO DEFENDANT (j) Whether or not at the time of the collision referred to in plaintiffs petition, this defendant was performing any business task or job at the request of or on behalf of defendants 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 plaintiff (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) Date, place and time taken; (b) Name and address of the person or persons connected with taking it; (c) Names and addresses of all persons present at the time it was taken; (d) Whether the statement was oral, written, shorthand, recorded, taped, etc.; (e) Was it signed? (f) Names and addresses of the persons or organizations under whose direction and upon whose behalf it was taken or made; (g) 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<<<<<<<<<********>>>>>>>>>>>>> 3 PLAINTIFFS APPROVED AUTO ACCIDENT INTERROGATORIES TO DEFENDANT 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) Describe each photograph, video, or movie; (b) State the date each was taken; (c) State the name and address of the person taking each such photo, video, or movie (d) 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 defendant expects to call as an expert witness at the trial, stating for each such expert: (i) Name; (ii) Address: (iii) Occupation; (iv) Place of Employment: (v) Qualifications to give an opinion (if such information if available on an experts curriculum vitae you may attach a copy thereof in lieu of answering this interrogatory subpart. (b) With respect to each expert listed, please state the subject matter on which the expert is expected to testify and the experts hourly deposition fee. (c) Identify each non-retained expert witness, including a party, who the defendant expects to call at trial who may provide expert witness opinion testimony by providing the experts name, address and field of expertise. State also any opinions the expert will testify to at trial. ANSWER: 3<<<<<<<<<********>>>>>>>>>>>>> 4 PLAINTIFFS APPROVED AUTO ACCIDENT INTERROGATORIES TO DEFENDANT 6. WITNESSES State the names and addresses of each person known by defendant, defendants representatives or defendants attorney to have witnesses 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 witnesses the occurrence. ANSWER: 7. WITNESS STATEMENTS State whether or not written or recorded statements have been obtained from any persons mentioned in the answers to Interrogatory Number 6 above with regard to the facts or circumstances surrounding the occurrence mentioned in these pleadings. If so, state the following: (a) The names, addresses and employers of persons whose statements were obtained; and (b) Name, address, employer, and job title of the person presently having control or custody of each statement. ANSWER: 8. CRIMINAL RECORD State whether defendant 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) The date of any such plea or conviction; 4<<<<<<<<<********>>>>>>>>>>>>> 5 PLAINTIFFS APPROVED AUTO ACCIDENT INTERROGATORIES TO DEFENDANT (b) The state and county where said plea or conviction occurred; (c) The offense for which defendant plead guilty or was convicted. ANSWER: 9. DESTINATION, ETC. State where defendant was coming from and the place of defendants destination at the time of the collision in question.; ANSWER: 10. AUTO OWNERSHIP AND PROPERTY DAMAGE (a) State the name and address of any and all registered or equitable owners of the vehicle being operated by defendant at the time of the occurrence in question. (b) 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: 11. VIOLATIONS State whether defendant or defendants representative was/were convicted of or pleaded guilty to any violation arising out of the collision in question, and if so, state the charges to which such person was convicted 5<<<<<<<<<********>>>>>>>>>>>>> 6 PLAINTIFFS APPROVED AUTO ACCIDENT INTERROGATORIES TO DEFENDANT or pled guilty, the name and address of the court where same occurred, the date of final disposition, and the cause number for each such plea or co
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