Sample Interrogatories Term paper
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CIVIL DISTRICT COURT FOR THE PARISH OF ORLEANS
STATE OF LOUISIANA
NO: DIVISION:
VERSUS
TOURO INFIRMARY
____________________ ________________________
FILED DEPUTY CLERK
PLAINTIFF'S INTERROGATORIES TO DEFENDANT
Plaintiff,, through undersigned counsel, propounds the following Interrogatories to defendant, Touro Infirmary, to be answered fully, separately, in writing, and under oath, within the delays allowed by law:
Interrogatory Number 1:
State when the accident referred to in the Petition for Damages first came to the attention of the defendant or any employee or company representative of the defendant, by whom it was reported, to whom it was reported, and the means used in the reporting, whether oral or in writing.
Interrogatory Number 2:
List the name, address, job title, employer, location, and activity at the time of the accident asserted by plaintiff of all persons known or believed by defendant to have:
a) Eyewitnessed or have been within sight or hearing of the accident;
b) First hand knowledge of the facts and circumstances of the accident or the events leading up to and following the accident, or of the conditions at the accident scene.
Interrogatory Number 3:
Provide the names and addresses of all persons (including but not limited to the plaintiff) from whom written or recorded statements, reports, memoranda, or testimony has been obtained by defendant or any person working on behalf of defendant, pertaining to the accident or damages asserted by plaintiff in the petition for damages, the events preceding the accident, and/or events following the accident, and identify the date of the taking of the statement(s), the location where the statement was taken and the person taking the statement(s).
Interrogatory Number 4:
Please explain in complete detail your routine inspection and maintenance procedures of all hospital beds, prior to and at the time of the incident made subject of this litigation.
Interrogatory Number 5:
Please state if any meetings or discussions were held or conducted before or after the incident in question, specifically regarding the procedure for locking and unlocking beds, identify the names of all participants, the subject matter of any such meetings or discussions, the person(s) providing any information or documentation, or bulletins, etc., discussed, all person(s) receiving any information or exchanging any information, the date(s) and times of the meeting(s) and any actions taken as the result of the meetings, or conclusions or policy changes made as a result of meetings.
Interrogatory Number 6:
Discuss, in detail, any and all policies, standards, regulations, and/or procedures promulgated by and/or adhered to by defendant, regarding the performance of bed weights of patients and safety procedures, if any,...
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