Johnson County District Courts Johnson County District Courts
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Local Court Rules |
<--- Appendix A
or Appendix C ---> Civil Appendix B Defendant's Interrogatories to Plaintiff, 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 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 ? ANSWER: 3. If applicable, furnish the following information with respect to such vehicle:
ANSWER: 4. If the vehicle being operated by you was being operated by someone other than the owner, then state:
ANSWER: 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. ANSWER: 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:
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 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. ANSWER: 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:
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. 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. ANSWER: 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. ANSWER: 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. ANSWER: 17. Have you been released from treatment? If so, state the date of such release. ANSWER: 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. ANSWER: 19. Are you claiming a wage or earnings loss as a result of the injuries you allege to have sustained? If so, state:
ANSWER: 20. State any other items of damages besides those previously mentioned which you are claiming. ANSWER: 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 your Petition)? Yes ______ No _______. If your answer is yes, state:
ANSWER: 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:
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:
ANSWER: 24. Have you made a claim under the Kansas Automobile Injury Reparations Act with your automobile insurance carrier? If so, state:
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.
_________________________ I hereby certify that the original and two copies of the above and foregoing Interrogatories to Plaintiff 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, 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___.
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