Republic ofthe Philippines REGIONAL TRIAL COURT BRANCH 14 Makaty, Metro Manila, Philippines ANGEL ©. LOCSINY Plaintitf, versus - CASE NO. 1234567890 FOR: DAMAGES DUE TO VEHICULAR ACCIDENT. RICHARD GUTIERREZ Defendant. WRITTEN INTERROGATORIES. Plaintiff's interrogatories To Defendant Plaintiff, Angel Locsin, by her attorneys, Ronald Mcdonalds, hereby propounds Interrogatories upon the Defendant, Richard Gutierrez, to fully, under oath, and in accordance with Civil Procedure, Rule 25, subject to the instructions set forth below: 1 Please state your full name, home address (and all addresses for the last five (5) years, social security number, date of birth, marital status and your employer's name and address. Include in your answer who was lived with you in the five S) year period before the accident. If you contend that the personal injuries of Plaintiff was not caused by the collision with your vehicle, state with particularity the facts upon which you base your contention. Please state the name and address of your employer, your position and duties, and your wages at the time of the auto accident and at the present time. Please state in detail your itinerary on the date of the auto accident, including each place at which you were present, your length of stay at each such place, and a detailed account of whom you saw and what you did at each such place. Please identify all persons known to you to have personal knowledge of the facts pertaining to the occurrence, and indicate those who were eye witnesses, and state the substance of their knowledge and articulate their expected testimony. Please identify all persons (excluding attorneys) who investigated the cause and circumstances of ‘this personal injury auto accident for you. Please identify all persons who arrived at the scene of the auto accident within one (1) hour after the auto accident.