Johnson County District Courts Johnson County District Courts
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Local Court Rules |
<--- Last Civil Rule
or Appendix B ---> Civil Appendix A Plaintiff's Interrogatories to Defendant, Automobile Accident IN THE DISTRICT COURT OF JOHNSON COUNTY, KANSAS
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1. State your full name, date of birth and place of birth.
2. If the vehicle being operated by you was being operated by someone other than the owner, then state:
ANSWER: 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. ANSWER: 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:
ANSWER: 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:
ANSWER: 6. Do you claim that anyone's fault should be compared other than those who are a party to this suit? If so, state:
ANSWER: 7. Have you given any statements, written, recorded or stenographic, to anyone concerning the occurrence described in the Petition? If so state:
ANSWER: 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. ANSWER: 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:
ANSWER: 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:
ANSWER: 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. ANSWER: 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:
ANSWER: 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. ANSWER: 14. Please state whether or not the defendant has liability insurance coverage for personal injury. If the answer is in the affirmative, state:
ANSWER: 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. ANSWER: 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:
ANSWER: 17. Except for this lawsuit, have you, in the last 10 years, had any other claim or suit filed against you?
If your answer is yes, state separately for each claim or suit.
ANSWER: 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. ANSWER: 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. ANSWER: 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 information:
ANSWER: 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.
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________________________ 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: ____________________________
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STATE OF KANSAS ) ______________________________ 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___.
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