This form is for plaintiffs. This unified set gives you not only interrogatories and demands form but also a solid foundation for drafting initial written discovery.
Six pages of tactical tips on drafting interrogatories, and demands for production of documents, physical items, and electronically stored information, in premises liability cases PLUS seven pages of form questions and demands for production of evidence-building materials.
Interrogatories & Demands for Production to Premises Liability Defendant gives you:
- A double-path, simultaneous approach: Combining your Interrogatories with simultaneous Demands for Production. Simultaneously with any interrogatories asking what exists, demand production of the items to be at the same time as the responses to the interrogatories are due. It’s a powerful technique for plaintiffs. This form shows you the way to do it.
- Time. A good legal form saves you time. This form gives you pattern discovery questions and demands. You cannot dictate or type these questions and demands as cheaply as buying a form and putting it into your word processor. Don’t reinvent the wheel, and don’t waste time when you have more important things to do. There are many interrogatory questions that plaintiffs should always ask. Don’t be caught short by omitting questions that top litigation counsel always ask, and do not waste time reinventing them for each case. Use a form to get those questions quickly into your interrogatories.
- “Best Practices”. Six pages of tips: from the best way to get your expert’s advice on your interrogatories without causing problems with his/her testimony at trial, to the best way to define “premises” in your discovery.
Use a form to auto-pilot much of the process of drafting written questions and demands for production. Of course, as a lawyer, you must determine for yourself our form’s fitness for your purpose, and apply your professional legal skills to drafting what your case needs. But 99% of the time, these questions and demands will be the foundation for your initial draft of interrogatories and requests for production in cases involving activities on real estate.
Our form is battle-tested. For example, our form reminds you:
The federal rules and most state rules on production of items now distinguish between three separate categories of physical items, to wit: (1) Documents, (2) Electronically Stored Information, and (3) Tangible Things. Use those category names with care.
And then our form uses those category names for your benefit.
Copy our interrogatory set into your word processor and you speed your drafting work, plus receiving battle-tested wording. You will benefit from interrogatories crafted like the following samples.
17. List any injury or claimed injury which occurred on Short Form’s Premises at or near the location of the Accident (whether or not the other injury or claim of injury was before or after the Accident). List:
- date of the injury or claimed injury
- nature of the injury or claimed injury,
- persons injured or making the claim of injury,
- if a lawsuit was brought in connection with the claimed injury,
- the title of the case and the court in which the case was filed, and
- identify who has a record of the injury or claimed injury.
18. List all tangible things, documents, or electronically stored information (whether made either before, at, or after the Occurrences) which show, measure, or record, (1) the area of the Occurrence; (2) persons involved in the Occurrence; (3) objects involved in the Occurrence; and (4) the events and happenings of the Occurrence. List:
- nature of the item,
- date of creation or collection of the item,
- the identity of who was involved in creation or collection of the item,
- who has the item,
- where the item is stored, and
- in what format it is stored.
And here, following, is a sample of the demands for production in this set. These requests get you information quickly, and these requests show your adversary that you know how to move quickly to get what you want!
Request for Production # 5. Produce any notes, records, documents (including photos and data recordings) electronically stored materials, or tangible items produced by the investigations, tests, experiments, or recreation/reconstruction of the Accident listed in your answer to Interrogatory 24 above.
RESPONSE: Yes __________ No__________ Attached __________
Request for Production # 6. Produce and allow us to inspect and copy any notes, records, documents (including photos and data recordings) electronically stored materials, or tangible items produced by the inspections listed in your answer to Interrogatory 26 above.
RESPONSE: Yes __________ No__________ Attached __________
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