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Civil Interrogatories

Civil Interrogatories

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Plaintiffs first set of interrogatories.
Plaintiffs first set of interrogatories.

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Published by: DaytonParalegals-dot-com on Mar 13, 2010
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05/24/2010

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PageThis form may be different from your state or county. Please refer to the rules in your jurisdiction. DaytonParalegals isnot responsible for irresponsible parties submitting the form on a “AS IS” basis. Check your Font and Size.
COURT OF COMMON PLEAS___________________ COUNTY, OHIO  __________________________________________________ 
______________________,Plaintiff,vs. ______________________,Defendant.)))))))) Case No. _____ (Judge ___________________)
PLAINTIFF'S FIRST SET
 
OF INTERROGATORIES
 
PROPOUNDED TO
 
DEFENDANT
 
 __________________________________________________  Pursuant to
 Rule 33 of the Ohio Rules of Civil Procedure
, Defendant is required to answer thefollowing interrogatories fully, in writing, and under oath, and to serve a copy of the Answer uponthe Plaintiff within twenty-eight (28) days from the date of receipt. A. Where the identity of a person is requested, state full name, home address, and also businessaddress, if known. B. Unless otherwise indicated, these interrogatories refer to the time, place and circumstances andoccurrences set forth in Plaintiff's Complaint. C. Where knowledge or information in possession of a party is requested, such a request includesknowledge of the party's agents, representatives, and employees. Where answer is made by acorporate Defendant, state the name, address and title of the person supplying the information aswell as the source of this information. D. The pronoun ''you'' refers to the party to whom these interrogatories are addressed and the persons mentioned in paragraph C above. E. You are under a duty to reasonably supplement your responses to these interrogatories, inaccordance with
 Rule 26(E) of the Ohio Rules of Civil Procedure.
 1. State the names, addresses, telephone numbers, and positions with the Defendant of each person who provided information for the answers of these interrogatories.  ______________________   ______________________  2. State the job title and job description of Plaintiff ___________________ withDefendant on or about [
date
].  ______________________ 
 
PageThis form may be different from your state or county. Please refer to the rules in your jurisdiction. DaytonParalegals isnot responsible for irresponsible parties submitting the form on a “AS IS” basis. Check your Font and Size.
 ______________________  3. State the name, address, and telephone number of each person known to Defendantwho witnessed in whole or in part the incident that occurred on ____________________[
date
], which is described in Paragraph 7-10 of the Complaintfiled herein.  ______________________   ______________________  4. State the name, address, and telephone number of any person known to Defendantwho submitted to Defendant any written complaint, warnings, comments, or any other statements relating in any way whatsoever to the design, safety features or defects inthe fork lift truck referred to in paragraph 10 of the Complaint.  ______________________   ______________________  5. State the name, address, and telephone number of any person known to Defendantwho made verbal complaints, comments, or other statements regarding the design,safety features, or defects in the fork lift truck referred to in paragraph 10 of thePlaintiff's Complaint.  ______________________   ______________________  6. State the name, address, and telephone number of the entity which manufactured thefork lift truck referred to in paragraph 10 of Plaintiff's Complaint.  ______________________   ______________________  7. State the name, address, and telephone number of the entity which designed the fork lift truck referred to in paragraph 10 of Plaintiff's Complaint.  ______________________   ______________________  8. When did Defendant purchase, lease, or otherwise acquire the fork lift truck referredto in paragraph 10 of Plaintiff's Complaint?  ______________________ 
 
PageThis form may be different from your state or county. Please refer to the rules in your jurisdiction. DaytonParalegals isnot responsible for irresponsible parties submitting the form on a “AS IS” basis. Check your Font and Size.
 ______________________  9. Identify in detail each modification or alteration made to the fork lift truck referredto in paragraph 10 of Plaintiff's Complaint following the date of acquisition.  ______________________   ______________________  10. State the name, address, and telephone number of any person known to Defendantwho sustained injury prior to ____________________[
date
], arising out of theoperation of the fork lift truck referred to in paragraph 10 of Plaintiff's Complaint.  ______________________   ______________________  11. Has Defendant ever had a regular maintenance schedule for the fork lift truck referred to in paragraph 10 of Plaintiff's Complaint? If so, set forth that maintenanceschedule.  ______________________   ______________________  12. On ____________________[
date
], were there any written warnings regarding proper operation of the fork lift truck referred to above? If so, please set forth the textof each such written warning.  ______________________   ______________________  13. State the name of plaintiff's immediate supervisor on ____________________[
date
].  ______________________   ______________________  14. Did Defendant conduct an investigation or inspection of the fork lift truck following the incident described in paragraph 7-10 of the Complaint?  ______________________   ______________________  

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