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Interrogatories From Defendant To Plaintiff - Kansas
| Interrogatories From Defendant To Plaintiff Form. This is a Kansas form and can be used in Civil 3rd Judicial District (Shawnee County) Local District Court . |
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F 3.201(2)B (Interrogatories from Defendant to Plaintiff) 1. Please provide the following information: a. Your full name and any other names or nicknames that you have used or gone by b. If your name has ever been legally changed state when, where and through what procedure and provide your original name; c. Your date of birth; d. Your place of birth; e. Your social security number; f. Your drivers license number. ANSWER: 2. State your present residential address and the period during which you have residedat this address. List all other addresses at which you have resided during the past ten (10) years andthe dates during which you resided at each address. ANSWER: 3. State the name and address of each school, college, or educational institution you haveattended, listing the dates of attendance for each. ANSWER: 4. State your present marital status; if you have previously been married, please list the<<<<<<<<<********>>>>>>>>>>>>> 2names and last known address of all former spouses, the dates of such marriages, the manner in whichthe former marriages were terminated and the caption of any divorce proceedings you have beeninvolved in. Please list the name, date of birth and current residential address of each of yourchildren. ANSWER: 5. For the ten (10) years immediately preceding the date of the filing of this lawsuit state: a. The names and addresses of each of your employers; b. The dates of commencement and termination of each such employment; c. Provide a detailed description of the services or work performed for each employment; d. Your average weekly wages or earnings from each place of employment; e. For each employer, whether a physical examination was required, and if so, state the date, place and person giving the physical examination; f. For each employer, whether or not you made any representations in writing or answered in writing any questions concerning your physical condition; g. The name of your immediate supervisor, foreman, boss or other superior to whom you were or are responsible at each of the places of employment. ANSWER: 6. Do you allege that you have lost any income from your business or occupation and/orany loss of earning capacity as a result of the occurrence referred to in your pleadings? If so, statethe following: <<<<<<<<<********>>>>>>>>>>>>> 3 a. The specific nature of your alleged injury that has caused such loss of income and/or loss of earning capacity; b. The number of days of income lost and the specific dates; c. The specific amount of any wages or income lost; d. The specific amount of any alleged loss of earning capacity; e. The amount of time, in your best judgment, that you will lose in the future; f. Set forth in detail the formula or method of computation of the alleged lost earnings, income or earning capacity; g. Provide the name and address of your supervisor who can verify each of these claims. ANSWER: 7. With respect to each of the past five (5) years, provide the following: a. Your gross income as reported on your income tax return; b. The name and address of the person, firm, or corporation having custody of any papers pertaining to your income for each of these years; c. The regional office of the Director of Internal Revenue with which each of your income tax returns was filed; d. The state tax authority or authorities with whom you filed income tax returns; e. The amount of tax shown to be due on each federal and state return. ANSWER: 8. Please state the name, address, business address, and telephone number of eachindividual likely to have discoverable information relevant to disputed facts alleged in the pleadingsand identify the subject of the information.<<<<<<<<<********>>>>>>>>>>>>> 4 ANSWER: 9. Please identify your current health insurance carrier and all past health insurancecarriers for the past ten (10) years and provide their address, telephone number, and the policy orgroup number for your policy with each carrier and the dates you were covered by each carrier. ANSWER: 10. Please state in detail the injuries and diseases you claim that you suffered as a resultof the occurrence referred to in your pleadings. ANSWER: 11. State the name, address and telephone number of each doctor, hospital, clinic,institution, social worker, counselor or other health care or mental health care professional whom youhave consulted or by whom you have been examined or treated for any physical, mental or emotionalinjury, damage or loss you claim to have been caused by any defendant in this action and state thedate of each contact with each such health care provider and provide a description of the injury ormalady for which examination or treatment was sought. ANSWER: 12. If you have incurred any bills or expenses in connection with the injuries, diseases ordamages you suffered because of the occurrence referred to in your pleadings, itemize the amountof each such bill or expense, describe the service for which the bill or expense was incurred, providethe date such expense was incurred and the identity and address of the person who rendered the billor who was involved in the expense. ANSWER: <<<<<<<<<********>>>>>>>>>>>>> 5 13. Except for the injuries complained of in the present lawsuit, have you at any timeeither before or after the date of the occurrence referenced in your pleadings, been injured, disabledor suffered an illness of any nature? If so, please state the following for each such illness, injury ordisability: a. The date, location and circumstance of the injury disability or illness; b. The precise nature of the injury, illness or disability; c. The names, addresses and telephone numbers of all hospitals, persons or medical providers who examined or treated you for those injuries, illnesses or disabilities; and d. If the injury, disability or illness was caused by an accident, the names, addresses and telephone numbers of any other parties or witnesses involved. ANSWER: 14. State the name, address and telephone number of each doctor, hospital, clinic,institution, social worker, counselor or other health care or mental health care professional whom youhave consulted or by whom you have been examined or treated at any time, both before and after theoccurrence in question, other than those by whom you have been examined or treated for injuriesalleged to have been sustained in this incident. State the date of each contact with each such healthcare provider and provide a description of the injury of malady for which examination
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