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 JOHN DOE,                                     )

            Plaintiff,                                )

                                                           )  Civil Action File 

vs.                                                      )  No. _______________

JANE ROE                                       )

           Defendant.                            )



            COMES NOW, Plaintiff in the above styled action, and serves these Interrogatories.


 1.                  "Defendant", or "you" or "your" or "yours" shall refer to and include Defendant, as well as agents, servants, employees, associates, investigators, attorneys, representatives, shareholders, directors, officers and all others who may have obtained information for or on behalf of those named above.

2.                  "Identify" or "state the identity of":

2.1.            When used in reference to a natural person means:  that person's full name, present or last known business and residence address, present or last known business and residence telephone number, present or last known occupation, employer, and position and that person's occupation or position during the time relevant to the particular interrogatory.

2.2.            When used in reference to an entity means:  its full and complete name, its type of entity (i.e., corporation, partnership, unincorporated association, trade name, etc.), the location of its principal place of business, its mailing address, and its telephone number.

2.3.            When used in reference to a document means:  a description of the type of document, the identity of the person or persons who authored, prepared, signed, and received the document, the date, title, and general description of the subject matter of the document, present location or custodian of the original and each copy of the document, the identity of any persons who can identify the document, and if a privilege is claimed, the specific basis for such claim, in addition to the information set forth above.

3.                  The word "document" is used herein in its broader sense to mean every book, document or other tangible thing, including without limitation the following items, whether printed, typed, recorded, photographed, filmed or reproduced by any process, namely:  agreements, communications, letters, memoranda, magnetic tapes, computer readable material, business records, notes, reports, photographs, and/or summaries of investigations, drawings, corporate records, desk calendars, appointment books, and any other information containing papers, writings or physical things.

4.                  The word "describe", used in connection with any act, occurrence, or physical facts, shall include but not be limited to the following:  the identity of every person known to have been involved in or to have witnessed the act or occurrence, the date or dates of any such act or occurrence, and a description of any documents, records, or things documenting or involved in such act, occurrence, or fact.

 5.                  The word “Incident” shall mean the facts and circumstances set forth in the Complaint giving rise to this action. 


            These interrogatories are served upon you pursuant to O.C.G.A. §9-11-33.  You are required to answer the following interrogatories separately and fully in writing under oath, within the time permitted by the provisions of the Georgia Civil Practice Act and to serve copies of your responses upon counsel for all parties.  These interrogatories are continuing and if at any time after you have answered these interrogatories, new or additional information responsive to any of these interrogatories comes to your attention, you are required to furnish such new or additional information to this propounding party and serve upon all counsel for all parties supplemental answers to these interrogatories in accordance with the provisions of the Georgia Civil Practice Act.

            These interrogatories, and answers hereto, are to include and are to be based upon, information in the possession of or gathered by you, your agents, servants, representatives, investigators, attorneys, and all other persons who have investigated or gathered information at your request or on your behalf.

            You are advised that the propounding party understands the attorney client privilege and the attorney work product privilege.  The propounding party is not seeking information which is truly attorney client or attorney work product privileged.  However, your response will be considered insufficient and a motion to compel will be filed if you respond generally that the information sought is attorney client or attorney work product privileged.  If in response to a particular interrogatory or request there is some information which is privileged and some information which is not privileged a general objection is not acceptable.  The propounding party is seeking only non-privileged information and documents.

            You are requested to respond to the following interrogatories:


You are advised that the following subparts are taken verbatim or are a close paraphrase from the local rules of the U.S. District Court of the Northern District of Georgia and are generally not considered objectionable interrogatories.  

a)      If you filed the Complaint state precisely the classification of the cause of action being filed, a brief factual outline of the case including your contentions as to what the other party or parties did or failed to do, and a succinct statement of the legal issues in the case.  If you have asserted defenses, provide a detailed factual basis for the defense or defenses you have asserted.

b)      Describe in detail all statutes, codes, regulations, legal principles, standards ad customs or usages, and illustrative case law which you contend are applicable to this action. 

c)      List the style and civil action number of any pending or previously adjudicated related cases. 

d)      Identify by full name, address, and telephone number all witnesses whom you will or may have at trial, including expert and impeachment witnesses.  For each lay witness, include a description of the issues to which the witness’ testimony will relate.   For each expert witness, state the subject matter on which the expert is expected to testify, the substance of the facts and opinions to which the expert is expected to testify, and a summary of the grounds for each opinion. 

e)      If you contend you have been injured or damaged, provide a separate statement for each item of damage, the dollar amount claimed, and citation to the statute, rule, regulation or case law authorizing a recovery for that particular item of damage. 

f)        Describe or produce for inspection each document in your custody or control or of which you have knowledge which you contend supports your claim or claims or your defenses.

g)      State the full name, address, and telephone number of all persons or legal entities who have a subrogation interest in or reimbursement claim against your claim or cause of action and state the basis and extent of such interest. 

h)      If you or any other party have been improperly identified, state the correct identification.

i)        Provide the names of any parties who you contend are necessary parties to this action, but who have not been named.  If you contend that there is a question of misjoinder of parties, provide the reasons for your contention.  

j)        If you contend that some other person or legal entity is, in whole or in part, liable to any other party in this matter, state the full name, address, and telephone number of such person or entity and describe in detail the basis of such liability. 

k)      Provide the names and addressed of all insurance companies that have liability insurance coverage relating to the matters alleged in any of the pleadings, the number or numbers of such policies, the amount of the liability coverage provided in each such policy, and the named insured on each policy. 



            Identify the individual executing the Verification of the responses to these interrogatories and identify all individuals who assisted in providing any information concerning or relating to your answers to these interrogatories.


            If you have ever been a plaintiff or defendant in any lawsuit other than this action, please state the title, docket number, and jurisdiction in which each lawsuit was filed, as well as the date each lawsuit was filed.


            If you are now or have ever been a party or involved in any other legal action or claim including but not limited to a mediation, arbitration, worker's compensation claims, social security disability claims, and insurance claims, identify the individual or entity before which the action or claim pended or is pending, the date the action or claim was initiated, whether you initiated the action or claim and provide any identifying numbers associated with the action or claim.


            Identify all persons who were witnesses to the incidents or events which are the subject matter of this lawsuit.  State the nature of the facts known by each such person.


            Identify any person who did not witness the incidents made the basis of this suit but who has knowledge of the incidents.  State the nature of the facts known by each such person and how they have obtained such knowledge.


            Identify each and every person whom you expect to call as an expert witness in the trial of this case and state specifically the subject matter upon which each expert is expected to testify, the substance of the facts and opinions to which each expert is expected to testify, and set forth a summary of the grounds of each and every opinion entertained by or formed by each and every expert witness.


            Identify any written or recorded statements or transcripts of oral statements of any person relevant to this action which you or your attorney possess or believe to exist, set forth the date on which any such statements were given, identify each individual present, identify each document recording or relating to such statements and identify the individuals or entities in possession of such documents.


            Identify each person, excluding your attorneys, to whom you have made any statement or with whom you have had any discussion regarding any aspect of this action, state the date and describe the substance of the statement or discussion.


            If you contend that any admission has been made by any party to this action, with respect to each such admission, describe and explain the substance and date thereof, identify the person or entity making the admission, and identify and describe all individuals who were witnesses or have knowledge regarding the admission.


            For each request for admission in the request for admissions served concurrently herewith for which your response is anything but an unqualified admission, state the facts and theories which support your denial, the individuals with knowledge of these facts and theories, and the documents which support or relate to these facts and theories.


            If you have insurance covering any of the claims made in the Complaint or which may cover any of the claims made in the Complaint, set forth the policy number(s), policy type, limits of coverage, and if the insurer has issued any notice regarding a reservation of rights or the like, describe and explain the notice and substance of same.


            If you claim the attorney work product privilege for any document identify the author, date of creation, possessor of the original, possessor of each copy, describe the nature of the document, and explain the purpose of the creation of the document whether in anticipation of litigation or otherwise.


            If you claim the attorney client privilege for any documents, other than correspondence to you from your lawyer, correspondence from you to your lawyer, and memoranda of conversations between you and your lawyer in which the only people present were you and your lawyer, for each such document identify the author, date of creation possessor of the original, possessor of each copy, describe the nature of the document, and explain the purpose of the creation of the document.


            For each affirmative defense set forth in your Answer set forth in detail each fact or theory and identify each document which supports or relates to such defense, identify each person with knowledge of each such fact setting forth the facts you believe each individual is aware of, and identify each person in possession each document identified. 


            Describe in detail the how the Incident occurred. 


            Describe and explain in detail all claims that have been made against you as a result of the Incident, identify each claimant, include in your response all amounts that have been paid to each claimant.  Identify all documents relating to each claim by each person identified.


            Were you hurt or injured in the Incident?  Identify each person involved in the Incident who was hurt or injured and describe their injuries.  Identify all documents regarding any injuries to each person identified. 


            What property damage occurred to your vehicle?  To each other vehicle involved in the Incident?  In your response provide the dollar amount and describe the damages to each vehicle involved in the Incident.  Identify all documents pertaining to any damage to any vehicle involved in the Incident. 


            Identify your employer, set forth your usual hours of employment, and set forth whether you were engaged in the course and scope of your employment at the time of the Incident. 


            Describe and explain in detail each drug (legal or illegal) you consumed in the 48 hour period immediately preceding the Incident.


            Describe and explain in detail all alcohol you consumed in the 24 hour period immediately preceding the Incident.


            Describe and explain the traffic court proceedings against you related to the Incident, describe and explain the results.  Include in your response your plea, whether a trial was held, who the witnesses were, and set forth the court's determination including sentence, fine, or other sanction.  Identify all documents pertaining to the traffic court proceedings. 


            Set forth all traffic violations you have had in the last 5 years.  Include in your response your plea, whether a trial was held, who the witnesses were, and set forth the court's determination including sentence, fine, or other sanction.


            Identify the owner of the vehicle you were driving at the time of the Incident.  Was the owner a member of your family?  Was the owner your employer?  Was the owner a person or entity you had an independent contracting relationship with.  Set forth with particularity where you were going at the time of the Incident, where you were coming from, any stops you had made along the way before the Incident, the purpose of your use of the vehicle you were driving, and whether you had permission from the owner to use the vehicle.


                                                                        LAW OFFICES OF

                                                                        DAVID J. REED





                                                                        David J. Reed

                                                                        State Bar No. 597601


1503 Bombay Lane

Oakbrook Centre

Roswell, GA  30076

(770) 751-0900



            I HEREBY CERTIFY that I have this day served counsel for all concerned parties with a copy of the within and foregoing pleading by depositing a copy of same in the United States Mail in a properly addressed envelope with sufficient postage affixed thereto to ensure delivery and addressed to:

Kenny Cheatham, Esq.

Dewey, Cheatham & Howe

5555 Gold Street

Atlanta, GA  30303


            This _____ day of January, 2000.



                                                                        David J. Reed


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Last modified: December 05, 2006