Interrogatories 2 with Answers from Car Accident Case

1. Pursuant to Illinois Supreme Court Rule 213(f), provide the name and address of each witness who will testify at trial and all other information required for each witness.

RYAN BACHNER, 210 Slalom Ct., Minooka, IL 60447. It is believed that this Defendant / Third Party Plaintiff is a lay witness who will testify to any and all aspects regarding how this traffic accident occurred and any issues relating to liability, including observations, lookout, speeds and directions of the vehicles involved, areas of contact involving said vehicles, the nature and extent of damages to the vehicles involved, positioning of the vehicles after the accident and any post-occurrence events.

ALICE LANGE, 2130 Saber Ct., Naperville, IL 60565. It is believed that the Plaintiff is a lay witness who will testify to any and all aspects regarding how this traffic accident occurred and her injuries claimed as a result of said occurrence.

ERIC LANGE, 2130 Saber Ct., Naperville, IL 60565. It is believed that this Third Party Defendant is a lay witnesses to this accident and will testify regarding his knowledge of how this traffic accident occurred and any issues relating to liability, including observations, lookout, speeds and directions of the vehicles involved, areas of contact involving said vehicles, the nature and extent of the damage to the Vehicles involved, positioning of the vehicles after the accident and any post-occurrence events.

NAPERVILLE POLICE OFFICER. OFFICER ID. 7825. It is believed that this individual is Naperville Police Officer who will testify to any and all facts regarding his investigation of this traffic accident as indicated in his police report, including time, location, layout of the accident scene, the names and addresses of the drivers, owners, and witnesses identified, areas of contact, observations regarding the positioning of the vehicles and the degree of damages sustained to the vehicles, and any conversations with the parties to the occurrence regarding each driver's conduct.

2. Identify the name and address of each and every witness who will offer independent expert testimony and with respect to each, please state:

a.) The subject matter on which the witness is expected to testify;

b.) The conclusions and opinions of each opinion witness and the basis thereof;

c.) the qualifications of each opinion witness; and

d.) Provide all reports of each opinion witness.

ANSWER: This Defendant has not determined as yet whether any independent expert witness will be called to testify at trial; investigation continues.

3. Identify the name and address of each and every controlled witness who will testify at trial and all other information required for each witness including:

a.) The subject matter on which the witness is expected to testify;

b.) The conclusions and opinions of each opinion witness and the basis thereof;

c.) the qualifications of each opinion witness; and

d.) Provide all reports of each opinion witness.

ANSWER: This Defendant has not determined as yet whether any controlled expert witness will be called to testify at trial; investigation continues.

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