STATE OF WISCONSIN CIRCUIT COURT _______ COUNTY

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PLAINTIFF NAME
ADDRESS
ADDRESS

Plaintiff,
Case No. __ CV ______
vs. Code No. 30101

DEFENDANT INSURER NAME

ADDRESS
ADDRESS, and

DEFENDANT DRIVER NAME

ADDRESS
ADDRESS,

Defendants,

and

HEALTH INSURER NAME

ADDRESS
ADDRESS,

Subrogated Party Defendant.

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PLAINTIFF’S FIRST SET OF WRITTEN INTERROGATORIES AND
REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANTS,
DEFENDANT INSURER NAME and DEFENDANT DRIVER NAME,
PURSUANT TO WISCONSIN STATUTES SECTIONS 804.08 AND 804.09
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PLEASE TAKE NOTICE that plaintiff requests each defendant to answer the following

Interrogatories and Request for Production of Documents, in writing and under oath, within forty-five

(45) days hereof, in accordance with Wisconsin Statutes Section 804.08, and to produce documents in

accordance with Wisconsin Statutes Section 804.09.

INSTRUCTIONS

Each interrogatory should be answered separately and fully, in writing, under oath, unless it is

objected to, in which event the reasons for objection must be stated in lieu of an answer. An evasive or

incomplete answer is deemed to be a failure to answer under Wisconsin Statute Section 804.12.
 Defendants are under a continuing duty to seasonably supplement responses with respect to

any question directly addressed to the identity and location of persons having knowledge of

discoverable matters, and the identity of each person expected to be called as a witness. Furthermore,

defendants are under a similar duty to correct any incorrect response when later learned that the

response was incorrect.

DEFINITIONS

The following terms are defined herein as follows, for purposes of these interrogatories: “You”

or “your” means DEFENDANT DRIVER NAME and/or DEFENDANT INSURER NAME representatives and

any successors or agents acting on behalf of said defendants; to “identify” a person means to state his or

her full name, last known address and employer’s name and address, if known to you; “date of accident

or incident” means DATE.

Whenever the words “the incident” or “the accident” are used in these Interrogatories, they

refer to the incident or the accident on or about DATE, wherein plaintiff suffered serious injuries.

Whenever the word “identify” is used in these Interrogatories and used in reference to an

individual person, it refers to and requires the following information: the full name, present home

address, if known, home telephone number, and his present position and business affiliation.

Whenever the word “identify” is used in these Interrogatories, and used in reference to a

person other than an individual, it refers to and requires the following information: whether such entity

is a corporation, partnership, or other organization, and the name, present and last known address and

principal place of business and telephone number.

Whenever the words “your company” are used in these Interrogatories, they refer to your

company, its subsidiaries, affiliates and merge acquired predecessors.

Whenever the words “document” and “documents” are used in these Interrogatories, they refer

to and mean all paper material of any kind, whether written, typed, printed, punched, filmed or marked

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in any way; recording tapes or wires; films; photographs, movies; or any graphic matter, however

produced or reproduced; and mechanical or electronic sound recordings or transcripts thereof.

Whenever the word “identify” is used in these Interrogatories, and is used in reference to a

document, it refers to and requires the following information: the date, the author (or, if different, the

signer or signers), the addressee, type of document (e.g. letter, memorandum telegram, chart, etc.) and

any other means of identifying it with sufficient particularity to meet the requirements for its inclusion

in a motion for production. If any such document was, but is no longer in your possession or subject to

your control, state what disposition was made of it and the reason for such disposition. In lieu of

identifying any document, a true and correct copy thereof may be annexed to and incorporated in the

answers to these Interrogatories.

All references to an “accident”, “occurrence” or “incident” in these interrogatories refer to an

accident occurring on STREET LOCATION, at a location known as CITY, STATE.

INTERROGATORIES AND REQUEST FOR PRODUCTION

OF DOCUMENTS TO DEFENDANT DRIVER NAME

INTERROGATORY NO. 1:  List the names and last known addresses of all persons who were

witnesses to the accident in question or who have knowledge of the facts leading up to and immediately

following the accident.

INTERROGATORY NO. 2:  List the names and last known addresses of all persons who have

knowledge of the injuries or damages sustained or claimed by plaintiff following the accident.

INTERROGATORY NO. 3:  In your own words, describe how the incident, which is the subject

matter of this lawsuit, occurred.

INTERROGATORY NO. 4: Please state whether or not you consumed any alcoholic beverages or

drugs or medications (prescribed or over-the-counter) of any kind whatsoever at any time within the

twenty-four (24) hours preceding the date and time of the occurrence. If your answer to this

interrogatory is in the affirmative, then please state:

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 (a) The name and address of all establishments or residents where you
consumed any such alcoholic drink or drug or medication at that said
time;

(b) The approximate hour and minute any such alcoholic drink or drug or
medication was consumed by yourself, and the length of time you were
present on the premises of all persons referred to in the previous
interrogatory, specifying the approximate time of your arrival and the
approximate time of your departure therefrom; and

(c) The type, brand, and quantity of each such alcoholic drink or drug or
medication consumed by you at that said time.

INTERROGATORY NO. 5: Were you and/or the vehicle you were driving at the time of the

accident equipped with either a mounted or portable cellular phone?

INTERROGATORY NO. 6: If your answer to the foregoing Interrogatory is in the affirmative,

please set forth:

(a) Did you place or receive any cellular calls or text messages on DATE, at any time
prior to the collision? If your answer is “yes,” identify all persons who were
either called or who placed calls or text messages to or from you during this
time period.

(b) Did you place or receive any cellular calls or text messages on DATE, at any time
subsequent to the collision? If your answer is “yes,” identify all persons who
were either called or who placed calls or text messages to you during this time
period.

(c) What cellular service provider did you use as of DATE?

INTERROGATORY NO. 7: Please state whether or not you have ever been convicted of a crime.

If your answer to this interrogatory is in the affirmative, then please state:

(a) Explain the nature of the offense(s) for which you were convicted and the
penalty received for each conviction;

(b) State the date of each conviction and the date on which each offense occurred;
and

(c) State the name of the City, County, and State where each conviction occurred.

INTERROGATORY NO. 8: As of the accident date, identify the name and address of your

employer, as well as your occupation.

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 INTERROGATORY NO. 9: If you were employed on the accident date, please indicate whether

you were performing any work duties as the part of any occupation or within the scope of your

employment at the time of the accident.

INTERROGATORIES AND REQUEST FOR PRODUCTION OF

DOCUMENTS TO DEFENDANT INSURER NAME

INTERROGATORY NO. 10:  State the names of all witnesses from whom DEFENDANT INSURER

NAME or any of its representatives have obtained written or recorded statements and the dates of such

statements.

INTERROGATORY NO. 11:  List the names and addresses of the custodians of the statements

identified in your answer to Interrogatory No. 10 and provide a copy of all such statements to plaintiff’s

attorney.

INTERROGATORY NO. 12:  State whether or not DEFENDANT INSURER NAME or any of its

representatives have taken photographs and/or videos concerning this matter. If so, state:

(a) The date of the photographs and/or videos;

(b) The custodian of the negatives or original photographs and/or videos;

and

(c) The nature of the subject matter depicted in the photographs and/or
videos.

(d) Provide a laser print of any and all photographs identified in your
answer to this interrogatory to plaintiff’s attorney, as well as a copy of
each video.

INTERROGATORY NO. 13:  State the total amount of insurance coverage or coverage's available

to DEFENDANT DRIVER NAME, directly or indirectly, which are applicable to the alleged accident in

question. Please state coverages by insurance company, name, coverage amount, and policy number.

Attach a copy of the original face sheet and endorsement thereto of each applicable policy of insurance

and provide a certified copy of each insurance policy to plaintiff’s attorney. This interrogatory is

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intended to include, but is not limited to, insurance coverage available through partnership agreements,

corporations, extended coverage, and so-called "umbrella" coverage.

INTERROGATORY NO. 14:  Please state the names and last known addresses of all agents,

servants or employees of said defendants who participated in any manner in the investigation of the

claim, which is the subject matter of this lawsuit. Provide a copy of all reports, records, memoranda and

all other documents relating to the investigation of plaintiff’s claim to plaintiff’s attorney.

INTERROGATORY NO. 15: Please state the name and current address of each individual

you intend to call as a witness (lay and expert witnesses) at the trial in this matter. In addition,

for each such witness, please state the following:

(a) A summary of the testimony he or she is expected to give.

INTERROGATORY NO. 16: Please identify any expert witness or witnesses you or

anyone, including your attorney acting on your behalf, has consulted or contacted, orally or in

writing, as to any liability question arising out of the occurrence referred to in plaintiff’s

complaint, stating each expert witness’ name, address and employer, and the exact nature of

the liability question involved.

INTERROGATORY NO. 17: Provide to plaintiff’s attorney copies of any and all exhibits

that defendants intend to utilize at trial in defense of their claim.

INTERROGATORY NO. 18: What limits of liability coverage did DEFENDANT INSURER

NAME have on the vehicle being driven by DEFENDANT DRIVER NAME at the time of the

accident, which is the subject of this lawsuit?

INTERROGATORY NO. 19: Did DEFENDANT INSURER NAME or any other company have

an umbrella policy covering the vehicle DEFENDANT DRIVER was driving at the time of the

accident, which is the subject of this lawsuit?

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 INTERROGATORY NO. 20: If your answer to the interrogatory immediately preceding

this interrogatory is in the affirmative, please state the name of the company providing such

coverage and the policy limits for such umbrella policy.

INTERROGATORY NO. 21: Did DEFENDANT INSURER NAME or any other insurance

company have a policy of insurance that would have covered DEFENDANT DRIVER NAME’s

driving on or about DATE?

Dated this ______ day of MONTH, YEAR.

FIRM NAME

By:_________________________________________
ATTORNEY NAME
Attorney for Plaintiff
State Bar No. _________

POST OFFICE ADDRESS:

FIRM ADDRESS