SAMPLE INTERROGATORIES Essay

This essay has a total of 862 words and 7 pages.

SAMPLE INTERROGATORIES



CIVIL DISTRICT COURT FOR THE PARISH OF ORLEANS

STATE OF LOUISIANA

NO: DIVISION:



VERSUS

TOURO INFIRMARY

____________________ ________________________
FILED DEPUTY CLERK

PLAINTIFF'S INTERROGATORIES TO DEFENDANT
Plaintiff,, through undersigned counsel, propounds the following Interrogatories to
defendant, Touro Infirmary, to be answered fully, separately, in writing, and under oath,
within the delays allowed by law:

Interrogatory Number 1:
State when the accident referred to in the Petition for Damages first came to the
attention of the defendant or any employee or company representative of the defendant, by
whom it was reported, to whom it was reported, and the means used in the reporting,
whether oral or in writing.


Interrogatory Number 2:
List the name, address, job title, employer, location, and activity at the time of the
accident asserted by plaintiff of all persons known or believed by defendant to have:

a) Eyewitnessed or have been within sight or hearing of the accident;
b) First hand knowledge of the facts and circumstances of the accident or the events
leading up to and following the accident, or of the conditions at the accident scene.


Interrogatory Number 3:
Provide the names and addresses of all persons (including but not limited to the
plaintiff) from whom written or recorded statements, reports, memoranda, or testimony has
been obtained by defendant or any person working on behalf of defendant, pertaining to the
accident or damages asserted by plaintiff in the petition for damages, the events
preceding the accident, and/or events following the accident, and identify the date of the
taking of the statement(s), the location where the statement was taken and the person
taking the statement(s).

Interrogatory Number 4:
Please explain in complete detail your routine inspection and maintenance procedures of
all hospital beds, prior to and at the time of the incident made subject of this
litigation.


Interrogatory Number 5:
Please state if any meetings or discussions were held or conducted before or after the
incident in question, specifically regarding the procedure for locking and unlocking beds,
identify the names of all participants, the subject matter of any such meetings or
discussions, the person(s) providing any information or documentation, or bulletins, etc.,
discussed, all person(s) receiving any information or exchanging any information, the
date(s) and times of the meeting(s) and any actions taken as the result of the meetings,
or conclusions or policy changes made as a result of meetings.


Interrogatory Number 6:
Discuss, in detail, any and all policies, standards, regulations, and/or procedures
Continues for 4 more pages >>




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