SAMPLE INTERROGATORIES essays

SAMPLE INTERROGATORIES essays CIVIL DISTRICT COURT FOR THE PARISH OF ORLEANS ____________________ ________________________ FILED DEPUTY CLERK PLAINTIFF'S INTERROGATORIES TO DEFENDANT Plaintiff,, through undersigned counsel, propounds the following Interrogatories to defendant, Touro Infirmary, to be answered fully, separately, in writing, and under oath, within the delays allowed by law: State when the accident referred to in the Petition for Damages first came to the attention of the defendant or any employee or company representative of the defendant, by whom it was reported, to whom it was reported, and the means used in the reporting, whether oral or in writing. List the name, address, job title, employer, location, and activity at the time of the accident asserted by plaintiff of all persons known or believed by defendant to have: a) Eyewitnessed or have been within sight or hearing of the accident; b) First hand knowledge of the facts and circumstances of the accident or the events leading up to and following the accident, or of the conditions at the accident scene. Provide the names and addresses of all persons (including but not limited to the plaintiff) from whom written or recorded statements, reports, memoranda, or testimony has been obtained by defendant or any person working on behalf of defendant, pertaining to the accident or damages asserted by plaintiff in the petition for damages, the events preceding the accident, and/or events following the accident, and identify the date of the taking of the statement(s), the location where the statement was taken and the person taking the statement(s). Please explain in complete detail your routine inspection and maintenance procedures of all hospital beds, prior to and ...