NOT LEGAL ADVICE, PRO SE DRAFT, CHECK LOCAL RULES
[Caption] · [Case no.]
First set of interrogatories from [propounding] to [answering]
Instructions: These are pattern questions. Observe your court’s numerical limits, definitions, and verification requirements.
- State your full legal name, aliases, date of birth, and current address.
- Identify every person who witnessed the incident or has knowledge of the facts alleged in the complaint.
- Identify every document, photograph, video, or electronic file that relates to the incident.
- Identify every healthcare provider who treated you for injuries claimed in this action, with dates.
- Itemize all claimed economic damages, including the amount, the payee, and whether the bill is outstanding.
- Identify every prior claim, lawsuit, or workers’ compensation matter involving bodily injury in the last ten years.
- Identify every insurance policy that may cover the incident, including policy numbers and limits if known.
- Describe any surveillance, social-media, or telematics data you know exists (dashcam, Ring, telematics, watches).