Plaintiff's Interrogatories to Defendant, Automobile Accident
IN THE DISTRICT COURT OF JOHNSON COUNTY, KANSAS
CIVIL COURT DEPARTMENT
) Case No.___________
) Div. No.________
INTERROGATORIES TO DEFENDANT
1. State your full name, date of birth and place of birth.
Date of birth
Place of birth
Social Security No.
Operators or Chauffeurs License No.
2. If the vehicle being operated by you was being operated by someone other than
the owner, then state:
a) The name and address of the owner;
b) The relationship between the owner and the driver with reference to the use of
3. Did you have any occupants in your vehicle at the time of the collision other
than yourself? If so, state the name, address and age of each other occupant.
4. Were you at the time of the occurrence or occurrences forming the basis of this
suit performing any job, task or undertaking for any person, firm or corporation
other than yourself? If your answer is yes, state:
a) The name and address of the person, firm or corporation for whom you were performing
some job, task or undertaking.
b) The nature of the job, task or undertaking you were performing for such person,
firm or corporation.
5. Were any statements, either written, recorded or stenographic obtained from plaintiff
by you or anyone acting in your behalf in connection with the occurrence described
in the petition? If so, state:
a) The dates they were obtained;
b) The name and address of each person obtaining such statements;
c) Describe the method by which the statement was taken;
d) If written, were they signed by the person?
e) The name and address of the present custodian or the statement;
f) If you will do so without a Request for Production, attach a copy of each statement
to your answers to these Interrogatories.
6. Do you claim that anyone's fault should be compared other than those who
are a party to this suit? If so, state:
a) The name, address and any other identification of any person, firm or corporation
for whom you claim was responsible;
b) The factual basis for your claim.
7. Have you given any statements, written, recorded or stenographic, to anyone concerning
the occurrence described in the Petition? If so state:
a) The dates they were given;
b) The name and address of each person taking such statements;
c) The name and address of the present custodian of the statement.
8. State the names and addresses of any and all persons known to you, your attorneys,
or any other representatives, who claim to have witnessed the occurrence that is
the subject of this action.
9. Were any statements, written or otherwise, obtained from anyone other than defendant
by a person acting on your behalf in connection with the occurrence described in
the Petition? If so, state:
a) The date of each statement;
b) The name and address of each person whose statement was taken;
c) Whether such statement was written, recorded or taken by any other means;
d) The name and address of each person who took such statements;
e) The name and address of the present custodian of the statements.
10. Do you, or anyone acting on your behalf, have any photographs of any objects
(e.g., scene, vehicles, etc.) that were taken since the occurrence described in
the Petition which relate or may relate to the occurrence described in the Petition?
If so, state:
a) The number of photographs you have;
b) The subject matter of each photograph;
c) The dates the photographs were taken;
d) The name and address of each photographer taking the photographs;
e) The name and address of the present custodian of the photographs.
11. Do you have any documentary evidence that you claim or may claim is relevant
to the issues of this action other than photographs (e.g., repair estimates, scene
diagrams, medical records, correspondence, etc.) or statements identified elsewhere
in your Interrogatory answers? If so, identify the same and produce a copy unless
you object to production without a Motion to Produce.
12. Do you, or anyone acting in your behalf, have a copy of any record of testimony
taken at a prior hearing involving this case? If so, state:
a) The date and nature of the hearing;
b) The name and address of the person who recorded the testimony;
c) The name and present address of the present custodian thereof.
13. Were you arrested or were any citations issued to you on charges arising out
of the occurrence described in the Petition? If so, identify the court wherein the
charges or citations were filed, and state the disposition of those charges or citations.
14. Please state whether or not the defendant has liability insurance coverage for
personal injury. If the answer is in the affirmative, state:
a) Whether or not the company with which you have insurance is defending this action;
b) The name and address of the insurance company defending the action;
c) The applicable limits of liability insurance contained in said policy.
d) Provide the name and address of each named insured under the policy.
15. Pursuant to K.S.A. 60-226, please provide the name and address of each person
whom you expect to call as an expert witness at trial, state the subject matter
about which the expert is expected to testify, and state the substance of the facts
and opinions as to which the expert is expected to testify along with a summary
of the grounds for each opinion.
16. Please state the name and address of the person currently in possession of the
vehicle you were operating. If the vehicle is no longer in your custody or your
right of control, please provide the following information:
a) The date the vehicle was last in your custody and right of control.
b) The name and address of the person or company to which custody of your vehicle
c) The amount of consideration, if any, paid to you for your vehicle.
d) The location of the vehicle at the present time or the last known location of
17. Except for this lawsuit, have you, in the last 10 years, had any other claim
or suit filed against you?
Yes __________ No ___________
If your answer is yes, state separately for each claim or suit.
a) Style of the suit, including court and case number.
b) A brief description of the nature of the suit.
c) Name of your attorney, if any.
d) Name and address of all other parties to the case.
18. Please indicate all states in which you have been licensed to drive, the approximate
date of the licensure and the driver's license number.
19. Please list all citations for moving violations which have been issued to you
during the 10 years preceding the occurrence described in the Petition indicating
the approximate date, the location, the specific charge, and the disposition.
20. Have you ever been involved in a vehicular collision during the 10 years preceding
the occurrence described in the Petition? If so, for each one, provide the following
c) The nature of the incident.
d) Were you issued any citations?
e) Whether or not a claim arose out of the collision.
Please take notice that a copy of your answers to the foregoing Interrogatories
must be served upon the undersigned within 30 days after service of these Interrogatories.
These Interrogatories shall be deemed continuing so as to require supplemental answers
if you or your attorneys obtain further information between the time answers are
served and the time of trial.
Attorney for Plaintiff
Certificate of Mailing
I hereby certify that the original and two copies of the above and foregoing Interrogatories
to Defendant were mailed this _______ day of _________, 20___, to:
Attorney for Plaintiff
STATE OF KANSAS )
COUNTY OF JOHNSON )
______________________________ of lawful age, being first duly sworn on his (her)
oath, deposes and says:
That he (she) is the defendant above-named, that he (she) has read the above and
foregoing Interrogatories, and that the answers thereto are true and correct according
to his (her) best information and belief.
Subscribed and sworn to before me this _______ day of _____________________ , 20___.