Defendant's Interrogatories to Plaintiff, Automobile Accident
IN THE DISTRICT COURT OF JOHNSON COUNTY, KANSAS
CIVIL COURT DEPARTMENT
) Case No.___________
) Div. No.________
INTERROGATORIES TO PLAINTIFF
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 applicable, were you the operator (passenger) of an automobile, ___________________,
license number, ________ _______________ which was involved in an accident with
the defendant at _________________________________, in the City of _________________,
Kansas, on _______________, 20 ?
3. If applicable, furnish the following information with respect to such vehicle:
a) The make and model of the vehicle;
b) The name and address of the owner of such vehicle.
4. 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
5. 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.
6. Were any statements, either written, recorded or stenographic obtained from defendant
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 of 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.
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 photograph;
e) The name and address of the present custodian of the photographs.
11. Do you have any documentary evidence you know of which 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 Request for Production.
12. Do you, or does 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. Pursuant to K.S.A. 60-226, please identify each person by name and address 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 and a summary of the grounds
of each opinion.
15. Do you claim to have suffered personal injuries in the occurrence described
in the Petition? If so, please describe the nature and extent of injuries you claim
and state those injuries which you claim are of a permanent nature.
16. Did you seek medical attention for such injuries? If so, state the name and
address of each doctor or entity who has attended you for such injuries, the dates
of such treatment, and the amounts charged for each treatment.
17. Have you been released from treatment? If so, state the date of such release.
18. Were you hospitalized as a result of the injuries claimed to have been sustained
in the occurrence described in the Petition? If so, state the names and addresses
of each hospital and dates of confinement and the charges incurred for each hospitalization.
19. Are you claiming a wage or earnings loss as a result of the injuries you allege
to have sustained? If so, state:
a) The name and address of your employer;
b) The nature of your work;
c) Your salary or wage basis;
d) The total amount of lost earnings claimed;
e) The dates you claim you were unable to work because of such injuries.
20. State any other items of damages besides those previously mentioned which you
21. Have you within the last 10 years suffered any injuries which required medical
treatment, consultation or examination (other than in the accident described in
Yes ______ No _______.
If your answer is yes, state:
a) The date and place such injury was sustained;
b) The type of accident involved;
c) The injuries you sustained;
d) Identify all medical practitioners who treated or examined you therefore.
22. Except for this lawsuit, have you within the last 10 years made claim or filed
suit for damages or compensation for personal injuries? Yes ____, No ____.
If your answer is yes, state:
a) First claim.
Date of injury ___________________
Name of your attorney, if any __________________
Name and address of party against whom made
Name of other party's insurer __________________
Court or agency where claim or suit filed, if any
b) Add separate page for all other claims, giving all information required above.
23. Have you received any payments from any insurer, government agency or other
third party payor as a result of injuries you sustained in the occurrence described
in the Petition? If so, state:
a) The name of the payor;
b) The amount of payment you have received.
24. Have you made a claim under the Kansas Automobile Injury Reparations Act with
your automobile insurance carrier? If so, state:
a) The name and address of the insurance carrier;
b) The amount you have claimed for medical and hospital expense;
c) The amount you have claimed as lost income;
d) Any other amounts you have claimed under the Kansas Automobile Injury Reparations
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 Defendant
I hereby certify that the original and two copies of the above and foregoing Interrogatories
to Plaintiff were mailed this _______ day of _________, 20___, to:
Attorney for Defendant
STATE OF KANSAS )
COUNTY OF JOHNSON )
______________________________ of lawful age, being first duly sworn on his (her)
oath, states: That he (she) is the plaintiff 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___.