Sample 213 Interrogatories to Defendant

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Defendant, Fairview Baptist Home, Inc's Interrogatories Pursuant to Supreme Court Rule 213(f)

Laura Lally, Myers, Miller & Krauskopf, Two North Lasalle Street, Suite 1200, Chicago, Illinois 60602, (312) 345-7250, (312) 345-7251 Fax, Firm No.: 37409, Attorneys for Defendant, Warren Barr, Nursing Pavilion, L.L.C.

NOW COMES the Defendant, WARREN BARR NURSING PAVILION, L.L.C., by and through their attorneys, MYERS, MILLER &* KRAUSKOPF and hereby propounds upon the plaintiff, MARY GRAVES, the following Interrogatories pursuant to Illinois Supreme Court Rule 213(f) to be answered within 28 days receipt hereof:

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

ANSWER:

2. Pursuant to Illinois Supreme Court Rule 213(f)(2), provide the name and address of each independent expert witness who will testify at trial and all other information required for each witness including:

a) The subject matter on which he/she will testify; and,

b) The opinions the party expects to elicit.

ANSWER:

3. Pursuant to Illinois Supreme Court Rule 213(f)(3), provide the name and address of each controlled expert witness who will testify at trial and all other information required for each witness including:

a) The subject matter on which the witness will testify;

b) The conclusions and opinions of the witness and the bases therefor;

c) The qualifications of the witness; and,

d) Identify and attach any reports prepared by the witness about the case.

ANSWER:

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