Interrogatories 3 sample interrogatories to defendant in products liability case

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Interrogatories to Defendant, Sybaris Clubs International, Inc., a corporation, Sybaris Ventures One, LLC, a corporation

Robert A. Clifford, Kevin P. Durkin, Richard F. Burke, Jr., Shannon M. McNulty, Clifford Law Offices, P.C., Attorneys for Plaintiff, 120 North Lasalle Street, Suite 3100, Chicago, Illinois 60602, (312) 899-9090, Attorney No.: 32640, Attorney for Plaintiff.

NOW COMES the Plaintiff, JENNIFER E. GARLAND, Independent Administrator of the Estate of SCOTT A. GARLAND, Deceased, herein and, pursuant to applicable Supreme Court Rules, propounds the following interrogatories upon the Defendants, SYBARIS CLUBS INTERNATIONAL, INC., a corporation, SYBARIS VENTURES ONE, LLC, a corporation, to be answered within 28 days:

1. State the name and address of the defendant, and, if different, give the full name and address of the individual signing the answers.

ANSWER:

2. State the full name and address of each person who witnessed or claims to have witnessed the occurrence alleged in the complaint.

ANSWER:

3. State the full name and address of each person not named (in 2 above) who was present or claims to have been present at the scene immediately before, at the time of, or immediately after said occurrence.

ANSWER:

4. Do you have any information tending to indicate:

a. That the Plaintiff's Decedent was, within the five years immediately prior to said occurrence, confined in a hospital, treated by a physician, or x-rayed for any reason other than personal injury? If so, give the name and address of each such hospital, physician, technician or clinic, the approximate date of such confinement or service, and state, in general, the reason for such confinement or service;

b. That the Plaintiff's Decedent had suffered serious personal injury prior to the date of said occurrence? If so, state when, where, and in general, the injuries suffered;

c. That the Plaintiffs Decedent has suffered either (a) any personal injury or (b) any serious illness, since the date of said occurrence? If so, for (a) state when, where and, in general, the injuries suffered; and for (b) state when he or she was ill and describe in general the illness;

d. That the Plaintiff's Decedent has ever filed any other suit for his or her own personal injuries? If so, give the court in which filed, the year filed, and the title and docket number of said case.

ANSWER:

5. Were any photographs taken of the scene of the occurrence or of the persons involved? If so, state the date or dates on which such photographs were taken, the subjects thereof, and who now has custody of them.

ANSWER:

6. Do you have statements from any witness other than yourself, or if a corporation, of anyone other than an officer, director, managing agent or foreman? If so, give the name and address of each such witness, the date of said statement, and state whether such statement was written or oral.

ANSWER:

7. List the names and addresses of all other persons (other than yourself and persons heretofore listed or specifically excluded) who have knowledge of the facts of said occurrence or of the injuries and damages following therefrom.

ANSWER:

8. Have the defendants, or any of their agents or attorneys, or any person acting on their behalf, obtained a statement from the plaintiff? If so, please attach a copy of said statement to your answers to these Interrogatories.

ANSWER:

9. Have the defendants, or any of their agents or attorneys, or any person acting on their behalf, obtained statements from any of the persons listed in answer to Interrogatories 2 and 3 above? If so, give the name and address of each person from whom a statement was obtained, whether written, oral, or otherwise.

ANSWER:

10. Are you the named insured in any policy of liability insurance issued and purporting to afford coverage for the occurrence complained of? If “yes”, specify as to each such policy, the insurance company issuing, the policy number, the effective period, the maximum amount of coverage afforded and the identity of all named insureds.

ANSWER:

11. Is any other individual or entity a named insured in any policy of liability insurance purporting to afford coverage for the occurrence complained of or purporting to afford liability coverage for occurrences at the premises in question as of the date of the occurrence. If “yes”, and if such individual or entity is not a party to this lawsuit, provide the identifying information specified in Interrogatory No. 10, above.

ANSWER:

12. State the full name and address of all persons, businesses, or other entities with any type of ownership or possessive interest in the aircraft N920MC.

ANSWER:

13. State the purpose of the trip for which aircraft N920MC was used on January 30, 2006, and identify the name of all persons involved in requesting and arranging for use of said aircraft on January 30, 2006.

ANSWER:

14. Please identify the current location of all maintenance records concerning aircraft N920MC, and identify the persons, entities or companies performing any maintenance on said aircraft during the five year period preceding January 30, 2006.

ANSWER:

15. Prior to January 30, 2006, was aircraft N920MC used by any employee of any Morgan Stanley company. If yes, please state each and every occasion said aircraft was used by Morgan Stanley, listing the date, time, pilots, passengers, and purpose for each use.

ANSWER:

16. Please identify the present location of any and all fuel receipts concerning aircraft N920MC for the trip on January 30, 2006, and for the five year period preceding January 30, 2006.

ANSWER:

17. Please identify and describe any and all fuel reimbursement agreements concerning aircraft N920MC for the use and operation of said aircraft on January 30, 2006, and the names and employers of all persons involved in such agreements.

ANSWER:

18. Please identify any and all policies of insurance covering or potentially applicable to Decedent Mark Turek on January 30, 2006.

ANSWER:

19. Please identify any and all policies of insurance covering or potentially applicable to Decedent Kenneth Knudson on January 30, 2006.

ANSWER:

20. Please identify any and all policies of insurance covering or potentially applicable to Decedent Scott Garland and Decedent Michael Waugh on January 30, 2006.

ANSWER:

21. Please describe and provide any and all manuals, written instructions, warnings, or procedures, that were provided with the purchase of the subject aircraft.

ANSWER:

22. Please describe and provide the certification history of the aircraft, but not limited to the dates and test results of all developmental ground tests and developmental flight tests.

ANSWER:

23. Please identify any and all individuals involved in and responsible for the design, testing, and certification of the subject air craft.

ANSWER:

24. Please identify any and all individuals who were involved in the investigation as a result of the subject air crash.

ANSWER:

25. Please identify all repairs, alterations, or modifications to the subject aircraft prior to June 30, 2006, and the name and address of the person, company or entity performing such work.

ANSWER:

26. Please identify all plans, proposals, recommendations, and suggestions for the repair, alteration, or modification to the subject aircraft prior to June 30, 2006, and the name of all persons, companies or entities involved therein.

ANSWER:

27. Please identify all business conducted by Kenneth Knudson, SYBARIS CLUBS INTERNATIONAL, INC., a corporation, or SYBARIS VENTURES ONE, LLC, a corporation during the trip on January 30, 2006, and all people Mr. Knudson met with, all locations visited and all persons or companies that provided transportation to him.

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