IN THE SUPERIOR COURT OF _______________ COUNTY
STATE OF GORGIA
,
Plaintiffs,
vs.
CIVIL ACTION NO.
,
__________________
Defendants.
PLAINTIFF(S) FIRST INTERROGATORIES TO DEFENDANT
Comes now _________________________, Plaintiff(s) in the above captioned case, and
files this his First interrogatories to Defendant(s) ___________________________, said
Interrogatories to be answered fully, completely and under oath within the time provided by law:
Definitions
A.
As used herein, “document” shall mean every writing or record of every type and
description that is or has been in possession, control, or custody of the defendants or of which the
defendants knowledge, including without limitation: correspondence, memoranda, letters,
papers, communications, tapes, stenographic or handwritten notes, studies, publications, books,
pamphlets, pictures, films, voice recordings, maps, graphs, charts, reports, surveys, minutes or
statistical compilations, or other data compilations from which information can be obtained or
translated, if necessary, into reasonably usable form by detection devices; every copy of such
writing or record if the original is not in the possession, custody or control of the defendants and
every copy of every such writing or record where the copy is not an identical copy of an original
[1 ]
or if the copy contains any commentary or notation whatsoever that does not appear on the
original.
B.
As used herein, “identify” or describe, when used in reference to:
1) An individual, shall mean to state his full name, present or last known address and
telephone number, present or last known employment address and telephone number,
and relationship to defendant. Whether the addresses and telephone numbers furnished as
herein described are the present or last known shall be specified.
2) A firm, partnership, corporation, proprietorship, association, or other organization or
entity, shall mean to state its full name and present or last known address (designating
which) and the legal form of the entity or organization.
3) A document shall mean to state the title (if any), date, author, sender, recipient, identity
of persons signing it, type of document (i.e., a letter, memorandum, notation, book, etc.)
or some other means of identifying it, and its present location and custodian. In the cas of
a document that was, but is no longer, in the possession, custody, or control of
defendants state what disposition was made of it, why, when, and by whom.
4) A fact shall mean to state the circumstances surrounding the fact, the person or persons
involved in the fact or circumstance, the date and location of the fact and an account of
the fact itself.
C.
As used herein, “person” shall mean an individual, firm, partnership, corporation,
proprietorship, association, governmental agency, or any other organization or entity. When
asked to identify a “person” who is an “individual” in an official position with a firm,
[2 ]
partnership, corporation, proprietorship, association, or other organization or entity, or
governmental agency, you should identify both the individual and that person’s relationship with
the firm, partnership, corporation, proprietorship, association, or other organization or entity or
governmental agency.
D.
As used herein, “date” shall mean the exact day, month, and year, if ascertainable, or if
not, the best available approximation (including the relationship to other events).
E.
As used herein, “Defendant,” or any synonym thereof, shall mean the Defendants in this
action and their officers, agents, servants, representatives, attorneys, insurance carriers or
adjusters, and any other person acting on their behalf, whether individually or collectively, who
have obtained, or who are in a position to obtain information for or on behalf of Defendants.
F.
As used herein, “fact” shall mean, without limitation, every thing, occurrence, event, or
state of affairs contended by Defendants to relate to the subject referenced by the party
propounding the interrogatories.
G.
As used herein, “Answer” shall mean the defensive pleadings filed by Defendants in the
above-styled action, as they may have been amended hereafter.
H.
As used herein, “rely” when used in reference to:
1) A fact shall mean all of those facts on which you depend in support of your legal claim as
well as all of those facts to which you refer to ascertain or support those facts.
[3 ]
2) A document, shall mean all of those documents on which you depend in support of your
legal claim as well as all of those documents to which you refer to ascertain or support
any facts on which you depend in support of your legal claim.
I.
As used herein, words importing the singular number may extend and be applied to
several persons or things, and vice versa. Words importing the masculine gender may be applied
to females or organizations.
Defendants may limit their responses to those specific alleged acts, omissions,
occurrences, circumstances, practices, or procedures on which they rely in this action and with
respect to which they will or may introduce evidence at trial or any hearing of this action. If an
entire question cannot be answered because the complete answer is not known, state and answer
the part known. Each of the following interrogatories shall be deemed to be continuing in the
manner provided by law. Defendants are requested (1) to supplement reasonably any response
directed to the identity and location of persons having knowledge of discoverable matters, as
well as the identity of each person expected to be called as an expert witness at trial, the subject
matter to which he is expected to testify and the substance of his testimony; and (2) to amend any
prior response if Defendants subsequently learn that although correctly made, the original
response is no longer true and circumstances are such that a failure to amend the response is, in
substance, a knowing concealment.
INTERROGATORY NO. 1
INTERROGATORY NO. 2
[4 ]
INTERROGATORY NO. 3
INTERROGATORY NO. 4
INTERROGATORY NO. 5
INTERROGATORY NO. 6
INTERROGATORY NO. 7
INTERROGATORY NO. 8
INTERROGATORY NO. 9
INTERROGATORY NO. 10
INTERROGATORY NO. 11
INTERROGATORY NO. 12
INTERROGATORY NO. 13
INTERROGATORY NO. 14
[5 ]
INTERROGATORY NO. 15
INTERROGATORY NO. 16
.
INTERROGATORY NO. 17
INTERROGATORY NO. 18
INTERROGATORY NO. 19
INTERROGATORY NO. 20
INTERROGATORY NO. 21
INTERROGATORY NO. 22
INTERROGATORY NO. 23
INTERROGATORY NO. 24
INTERROGATORY NO. 25
[6 ]
Respectfully submitted, this ________ day of ________, 20_____.
_________________________
Name
Attorney for Plaintiff(s)
State Bar No.
Street Address,
City GA, ZIP
Phone Number
[7 ]