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Kaylea Yunes

First Set of Interrogatories

IN THE UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF COLORADO

Civil Action No. XX-XX-00147

SARAH ROBERTSON, a Minor


By Her Next of Friends, CAROL
ROBERTSON AND KURT ROBERTSON
4672 Empire Court
Starville, Brockton 00011
Plaintiff,
v.

MARVIN ADCOCK and


HELEN ADCKOCK
7676 Brent Drive
Starville, Brockton 00011
Defendant.

DEFENDANTS FIRST SET OF INTERROGATORIES, REQUEST FOR


PRODUCTION AND REQUEST FOR ADMISSIONS TO PLAINTIFFS

Pursuant to Rules 33, 34 and 36 of the Colorado Rules of Civil Procedure, you are to

answer the interrogatories hereinafter set forth, separately, full, in writing, and under

oath. You should deliver a true copy of your answer to the undersigned attorney within 30

days after the date of service of these interrogatories.

DEFINITIONS

Words in BOLDFACE CAPITALS in these interrogatories are defined as follows:

(a) INCIDENT includes the circumstances and events surrounding the alleged accident,

injury, or other occurrence or breach of contract giving rise to this action or proceeding.

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(b) YOU OR ANYONE ACTING ON YOUR BEHALF includes Sarah Robertson, Carol

and Kurt Robertson, your attorneys, and anyone else acting on your behalf.

(c) PERSON includes a natural person, firm, association, organization, partnership,

business, trust, corporation, or public entity.

(d) DOCUMENT means a writing, as defined in CRE 1001 and includes the original or a

copy of handwriting, typewriting, printing, photostating, photographing, and every other

means of recording upon any tangible thing and form of communicating or

representation, including letters, words, pictures, sounds, or symbols, or combinations of

them.

(e) HEALTH CARE PROVIDER includes any PERSON or entity referred to as a "Health

Care Professional" or "Health Care Institution" in C.R.S. 13-64-202(3) and (4).

(f) ADDRESS means the street address, including the city, state, and zip code.

INSTRUCTIONS
A. You are required by Rule 33 of the Colorado Rules of Civil Procedure to answer fully and

factually each of the interrogatories hereinafter set out, furnish all information called for

by said interrogatory, sign your response, swear to your response and serve same upon

the undersigned attorney within thirty (30) days after the date of service of these

interrogatories. You are further instructed:


B. Every interrogatory herein shall be deemed a continuing interrogatory, and you are to

supplement your answers promptly if and when you obtain relevant information in

addition to, or in any way inconsistent with, your initial answer to any interrogatory.
C. If you object to, or otherwise decline to answer, any portion of an interrogatory, provide

all information called for in that portion of the interrogatory to which you do not object or

which you do not decline to answer. If you object to an interrogatory on the grounds that

to provide an answer would constitute an undue burden, provide such requested

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information as can be supplied without undertaking an undue burden. For those portions

of any interrogatory to which you object or otherwise decline to answer, state the reason

for such objection or declination.


D. The applicable period of time, unless otherwise provided, shall be from thirty days (30) to

the date of answering these interrogatories.


E. If any answer is refused in whole or in part, on the basis of a claim of privilege or

exemption, state the following:


a. The nature of the privilege or exemption claimed;
b. The general nature of the matter withheld (e.g., substance of

conversation of the withheld information, name of originator);


c. Name(s) of person(s) to whom the information has been imparted; and
d. The extent, if any, to which the information will be provided subject to

the privilege or exemption.

PATTERNED INTERROGATORIES

1.0 Identity of Persons Answering These Interrogatories

[] 1.1 State the name, ADDRESS, telephone number, and relationship to you of each

PERSON who prepared or assisted in the preparation of the responses to these

interrogatories. (Do not identify anyone who simply typed or reproduced the responses.)

2.0 General Background Information Individual

[] 2.12 At the time of the INCIDENT, did you or any other person have any physical,

emotional, or mental disability or condition that may have contributed to the occurrence

of the INCIDENT?

If so, for each person state:

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(a) The name, ADDRESS, and telephone number;


(b) The nature of the disability or condition;

(c) The manner in which the disability or condition contributed to the occurrence

of the INCIDENT.

4.0 Insurance

[] 4.1 At the time of the INCIDENT, was there in effect any policy of insurance through

which you were or might be insured in any manner (for example, primary, pro-rata, or

excess liability coverage or medical expense coverage) for the damages, claims, or

actions that have arisen out of the INCIDENT?

If so, for each policy state:

(a) The kind of coverage;

(b) The name and ADDRESS of the insurance company;

(c) The name, ADDRESS, and telephone number of each named insured;

(d) The policy number;

(e) The limits of coverage for each type of coverage contained in the policy;

(f) Whether any reservation of rights or controversy or coverage dispute exists

between you and the insurance company;

(g) The name, ADDRESS, and telephone number of the custodian of the policy.

6.0 Physical, Mental, or Emotional Injuries

[] 6.1 Do you attribute any physical, mental, or emotional injuries to the INCIDENT.

If your answer is "no," do not answer interrogatories 6.2 through 6.7.

[] 6.2 Identify each injury you attribute to the INCIDENT and the area of your body

affected.

[] 6.3 Do you still have any complaints that you attribute to the INCIDENT?

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If so, for each complaint state:

(a) A description;
(b) Whether the complaint is subsiding, remaining the same, or becoming worse;
(c) The frequency and duration.

[] 6.4 Did you receive any consultation or examination (except from expert witnesses

covered by C.R.C.P. 35 or treatment from a HEALTH CARE PROVIDER for any injury

you attribute to the INCIDENT?

If so, for each HEALTH CARE PROVIDER state:

(a) The name, ADDRESS, and telephone number;

(b) The type of consultation, examination, or treatment provided;

(c) The dates you received consultation, examination, or treatment;

(d) The charges to date.

[] 6.5 Have you taken any medication, prescribed or not, as a result of injuries that you

attribute to the INCIDENT?

If so, for each medication state:

(a) The name;

(b) The PERSON who prescribed or furnished it;

(c) The date prescribed or furnished;

(d) The dates you began and stopped taking it;

(e) The cost to date.

[] 6.6 Are there any other medical services not previously listed (for example, ambulance,

nursing, prosthetics)?

If so, for each service state:

(a) The nature;

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(b) The date;

(c) The cost;

(d) The name, ADDRESS, and telephone number of each provider.

[] 6.7 Has any HEALTH CARE PROVIDER advised that you may require future or

additional treatment for any injuries that you attribute to the INCIDENT?

If so, for each injury state:

(a) The name and ADDRESS of each HEALTH CARE PROVIDER;

(b) The complaints for which the treatment was advised;

(c) The nature, duration, and estimated cost of the treatment.

10.0 Medical History

[] 10.1 At any time before the INCIDENT, did you have complaints or injuries that

involved the same part of your body claimed to have been injured in the INCIDENT?

If so, for each state:

(a) A description;

(b) The dates it began and ended;

(c) The name, ADDRESS, and telephone number of each HEALTH CARE

PROVIDER whom you consulted or who examined or treated you.

[] 10.2 List all physical, mental, and emotional disabilities you had immediately before

the INCIDENT. (You may omit mental or emotional disabilities unless you attribute any

mental or emotional injury to the INCIDENT.)

[] 10.3 At any time after the INCIDENT, did you sustain injuries of the kind for which

you are now claiming damages?

If so, for each incident state:

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(a) The date and the place it occurred;

(b) The name, ADDRESS, and telephone number of any other PERSON involved;

(c) The nature of any injuries you sustained;

(d) The name, ADDRESS, and telephone number of each HEALTH CARE

PROVIDER that you consulted or who examined or treated you;

(e) The nature of the treatment and its duration.

12.0 Investigation General

[] 12.1 State the name, ADDRESS, and telephone number of each individual:

(a) Who witnessed the INCIDENT or the events occurring immediately before or

after the INCIDENT;

(b) Who made any statement at the scene of the INCIDENT;

(c) Who heard any statements made about the INCIDENT by any individual at the

scene;

(d) Who YOU OR ANYONE ACTING ON YOUR BEHALF claims to have

knowledge of the INCIDENT (except for expert witnesses covered by C.R.C.P.

26(a)(2) and (b)(4)).

[] 12.2 Have YOU OR ANYONE ACTING ON YOUR BEHALF interviewed any

individual concerning the INCIDENT?

If so, for each individual state:

(a) The name, ADDRESS, and telephone number of the individual interviewed;

(b) The date of the interview;

(c) The name, ADDRESS, and telephone number of the PERSON who conducted

the interview.

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[] 12.3 Have YOU OR ANYONE ACTING ON YOUR BEHALF obtained a written or

recorded statement from any individual concerning the incident?

If so, for each statement state:

(a) The name, ADDRESS, and telephone number of the individual from whom the

statement was obtained;

(b) The name, ADDRESS, and telephone number of the individual who obtained

the statement;

(c) The date the statement was obtained;

(d) The name, ADDRESS, and telephone number of each PERSON who has the

original statement or a copy.

[] 12.4 Do YOU OR ANYONE ACTING ON YOUR BEHALF know of any

photographs, films, or videotapes depicting any place, object, or individual concerning

the INCIDENT or plaintiff's injuries?

If so, state:

(a) The number of photographs or feet of film or videotape;

(b) The places, objects, or persons photographed, filmed, or videotaped;

(c) The date the photographs, films, or videotapes were taken;

(d) The name, ADDRESS, and telephone number of the individual taking the

photographs, films, or videotapes;

(e) The name, ADDRESS, and telephone number of each PERSON who has the

original or a copy.

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[] 12.5 Do YOU OR ANYONE ACTING ON YOUR BEHALF know of any diagram,

reproduction, or model of any place or thing (except for items developed by expert

witnesses covered by C.R.C.P. 26(a)(2) and (b)(4)) concerning the INCIDENT?

If so, for each item state:

(a) The type (i.e., diagram, reproduction, or model);

(b) The subject matter;

(c) The name, ADDRESS, and telephone number of each PERSON who has it.

[] 12.6 Was a report made by any PERSON concerning the INCIDENT?

If so, state:

(a) The name, title, identification number, and employer of the PERSON who

made the report;

(b) The date and type of report made;

(c) The name, ADDRESS, and telephone number of the PERSON for whom the

report was made.

17.0 Responses to Request for Admissions

[] 17.1 Is your response to each request for admission served with these interrogatories an

unqualified admission?

If not, for each response that is not an unqualified admission:

(a) State the number of the request;

(b) State all facts upon which you base your response;

(c) State the names, ADDRESSES, and telephone numbers of all PERSONS who

have

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Knowledge of those facts;

(a) Identify all DOCUMENTS and other tangible things that support your

response and state the name, ADDRESS, and telephone number of the

PERSON who has each DOCUMENT or thing.

NON-PATTERNED INTERROGATORIES

1.0 Describe with particularity what YOU were doing immediately before the dog bit

you. Include surrounding, activities and any other relevant information.


2.0 Describe with particularity any previous encounters, meaning earlier that day or any

time in the past, YOU had with the dog.


3.0 Describe in detail any food items that may have been in contact with, around, or on

YOU at any time during the INCIDENT.


4.0 Describe in detail any previous encounters with any other dogs YOU may have had

prior to the INCIDENT.


5.0 Describe in detail any pets YOU have owned previously to the INCIDENT; provide a

full description of the animal and their mannerisms and characteristics.

REQUEST FOR PRODUCTION

1.0 Produce all documents evidencing any physical, emotional, or mental disability or

condition that may have contributed to the occurrence of the INCIDENT.


2.0 Produce all documents evidencing any policy of insurance through which you were or

might be insured in any manner for the damages, claims, or actions that have arisen

out of the INCIDENT.


3.0 Produce all documents evidencing any physical, mental, or emotional injuries to the

INCIDENT.
4.0 Produce all documents evidencing any continued physical, mental or emotional

injuries to the INCIDENT.


5.0 Produce all documents evidencing any consultation or examination or treatment from

a HEALTH CARE PROVIDER, for any injury you attribute to the INCIDENT.

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6.0 Produce all documents evidencing future or additional treatment for any injuries that

you attribute to the INCIDENT.


7.0 Produce all documents evidencing any other damages that you attribute to the

INCIDENT.
8.0 Produce any documents evidencing any complaints or injuries that involved the same

part of your body claimed to have been injured in the INCIDENT.


9.0 Produce any documents evidencing any physical, mental and emotional disabilities

you had immediately before the INCIDENT.


10.0 Produce any documents evidencing any medication, prescribed or not, as a result of

injuries that you attribute to the INCIDENT.


11.0 Produce any documents evidencing any other medical services not previously listed

that you attribute to the INCIDENT.


12.0 Produce any documents evidencing any injuries sustained after the INCIDENT that

you are now claiming damages.


13.0 Produce all documents evidencing any witnesses to the INCIDENT, and their

address.
14.0 Produce all documents that YOU OR ANYONE ACTING ON YOUR BEHALF

have interviewed any individual concerning the INCIDENT.


15.0 Produce any written or recorded statements from any individual concerning the

INCIDENT.
16.0 Produce any photographs, films, or videotapes depicting any place, object or

individual concerning the INCIDENT or plaintiffs injuries.


17.0 Produce any diagram, reproduction or model of any place or thing concerning the

INCIDENT.
18.0 Produce all documents evidencing a report or reports made by any PERSON

concerning the INCIDENT.


19.0 Produce any documents evidencing the inspection of the scene of the INCIDENT.

REQUEST FOR ADMISSIONS

1.0 Admit that the documents produced by YOU in response to Defendants First Set of

Discovery Requests are true and authentic.

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2.0 Admit that all statements made in answer to all interrogatories listed herein are true

and authentic.
3.0 Admit that YOU obtained no permanent damage or injury, physical, emotional or

otherwise.
4.0 Admit that YOU pulled on the dogs tail while the dog was eating.
5.0 Admit that YOU were advised to not pull on the dogs tail.
6.0 Admit that YOU were advised to not ride the dog like a horse.

Harry Best
Trial Attorney for Defendant
Best, Simpleton & Alright
473 Court Street
Starville, Brockton 00011
555-555-4444
Attorney Registration # 00045825

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CERTIFICATE OF SERVICE

I certify that on April 21, 2016 a copy of the Defendants First Set of Interrogatories,

Request for Production and Request for Admissions to Plaintiffs was delivered to the

parties listed below by hand delivery.

CAROL ROBERTSON AND KURT ROBERTSON

4672 Empire Court

Starville, Brockton 00011

Signature:

Printed Name:

Title (if applicable):

Address:

Telephone:

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