Interrogatory Pevensie V
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STATE OF NORTH CAROLINA
IN THE GENERAL COURT OF JUSTICE
COUNTY OF GASTON
LUCY PEVENSIE, Plaintiff,
DISTRICT COURT DIVISION FILE NUMBER 19-CVD-425
) ) )
PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT
) vs.
MICHAEL TUMNUS, Defendant.
) )
) )
THE PLAINTIFF requests that the DEFENDANT produce the following documents and things in your possession, custody or control in accordance with Rules 26 and 34 of the North Carolina Rules of Civil Procedure for inspection and copy at the office of Kathryn Taylor, Attorney for the Plaintiff, located at 123 Main Street, Gastonia NC 28054, within 30 days of the date on the Certificate of Service. In lieu of production of documents for copying, the Defendant may attach hereto exact copies (hard copies; delivery by CD or electronic delivery) of all requested documents clearly designating each request to which each document pertains and mail or deliver them to Kathryn Taylor, Attorney for Plaintiff, at the above address.
INSTRUCTIONS: PLEASE TAKE NOTICE that pursuant to Rule 33 of the North Carolina Rules of Civil Procedure, you are hereby requested to serve answers under oath and within thirty (30) days to the following interrogatories. These interrogatories shall be deemed to be continuing in nature and should the answers to any of these Interrogatories change prior to the time of trial, you shall give notice of all changes. 1. These Interrogatories are continuing in character so as to require you to file supplementary answers if you obtain further or different information before trial. 2. Unless otherwise stated, these Interrogatories refer to the time, place, and circumstances of the auto accident and personal injuries mentioned or complained of in the Complaint. 3. Where name and identity of a person is required, please state full name, home address and also business address, if known. 4. Where knowledge or information in possession of a party is requested, such request includes knowledge of the party's agents, representatives, and unless privileged, his attorney's. When answer is made by corporate defendant, state the name, address and title of persons supplying the information and making the affidavit, and announce the source of his or her information.
DEFINITIONS: 1
1.
The pronoun "you" refers to the party to whom the Interrogatories are addressed (the Defendant).
2.
"Identify" when referring to an individual, corporation, or other entity shall mean to set forth the name and telephone number, and if a corporation or other entity, its principle place of business, or if an individual, the present or last known home address, his or her job title or titles, by whom employed and address of the place of employment.
3.
“Accident” is defined as the accident that resulted in injury to the Plaintiff’s person which occurred on February 3rd, 2019 as referenced in the Plaintiff’s Complaint. INTERROGATORIES: PLEASE TAKE NOTICE that pursuant to Rule 33 of the North Carolina Rules of Civil Procedure, you are hereby requested to serve answers under oath and within thirty (30) days to the following interrogatories. These interrogatories shall be deemed to be continuing in nature and should the answers to any of these Interrogatories change prior to the time of trial, you shall give notice of all changes. 1.
State your full name and address and all aliases by which you have been known to any individual or any entity.
2.
State your date of birth, social security number, current mailing address, and physical address.
3.
State the name and address of your employer (if applicable), the contact information for your supervisor, your position and duties, and your wages at the time of the auto accident and at the present time.
4.
Please identify all persons (excluding attorneys) who investigated the cause and circumstances of this accident for you.
5.
Please identify all persons to whom you have given signed statements regarding the accident, the date thereof, and the name of the person in whose custody each is at this time.
6.
Please state whether you have within your possession or control photographs, plats, or diagrams of the scene of the auto accident or objects connected with said motor vehicle accident, stating what those objects are.
7.
State in detail your itinerary on the date of the accident, including each place at which you were present, your length of stay at each such place, and a detailed account of whom you saw and what you did at each such place.
8.
Please give a concise statement of facts as to how you contend the accident took place.
9.
Please state whether you consumed any drugs, medicines, or alcoholic beverages within twenty-four (24) hours prior to said occurrence, the place where such drugs, medicines, or alcoholic beverages were obtained, the nature of the drugs, medicines, or alcoholic beverages, and the amount thereof. 2
10.
Please state whether you were under the care of a physician at the time of the accident. If so, please state the name and address of your physician, specify the illness or condition for which you were treated, and list any prescribed medication.
11.
If you and the Plaintiff had any conversation after the accident, please state the substance of any such conversation.
12.
If any members of your family or anyone else had any conversations with the Plaintiff, please state to the best of your knowledge the place of such conversations and the nature of such conversations.
13.
Please state in detail all actions you took or attempted to take to avoid the accident.
This the 28th of March, 2019
____________________________
Kathryn A. Taylor Attorney for the Plaintiff 123 Main Street Gastonia, NC 28052 Telephone: (704) 285-0277 Telecopier: (704) 987-654
CERTIFICATE OF SERVICE
3
Certified on the 28th day of APRIL 2019, I have served a copy of the foregoing PLAINTIFFS FIRST SET OF INTERROGATORIES TO DEFENDANT by mailing via the United States Postal Service Certified Mail a copy thereof to the person or acceptable agent thereof hereinafter named below:
TO:
Michael Tumnus Defendant 1308 Winter Drive Narnia, NC 28021
________________________________ KATHRYN A. TAYLOR ATTORNEY FOR THE PLATINTIFF 123 MAIN STREET POST OFFICE BOX 1950 GASTONIA, NC 280521950 TELEPHONE: (704) 28050277 TELECOPIER: (704) 987654
4
IN THE GENERAL COURT OF JUSTICE
COUNTY OF GASTON
LUCY PEVENSIE, Plaintiff,
DISTRICT COURT DIVISION FILE NUMBER 19-CVD-425
) ) )
PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT
) vs.
MICHAEL TUMNUS, Defendant.
) )
) )
THE PLAINTIFF requests that the DEFENDANT produce the following documents and things in your possession, custody or control in accordance with Rules 26 and 34 of the North Carolina Rules of Civil Procedure for inspection and copy at the office of Kathryn Taylor, Attorney for the Plaintiff, located at 123 Main Street, Gastonia NC 28054, within 30 days of the date on the Certificate of Service. In lieu of production of documents for copying, the Defendant may attach hereto exact copies (hard copies; delivery by CD or electronic delivery) of all requested documents clearly designating each request to which each document pertains and mail or deliver them to Kathryn Taylor, Attorney for Plaintiff, at the above address.
INSTRUCTIONS: PLEASE TAKE NOTICE that pursuant to Rule 33 of the North Carolina Rules of Civil Procedure, you are hereby requested to serve answers under oath and within thirty (30) days to the following interrogatories. These interrogatories shall be deemed to be continuing in nature and should the answers to any of these Interrogatories change prior to the time of trial, you shall give notice of all changes. 1. These Interrogatories are continuing in character so as to require you to file supplementary answers if you obtain further or different information before trial. 2. Unless otherwise stated, these Interrogatories refer to the time, place, and circumstances of the auto accident and personal injuries mentioned or complained of in the Complaint. 3. Where name and identity of a person is required, please state full name, home address and also business address, if known. 4. Where knowledge or information in possession of a party is requested, such request includes knowledge of the party's agents, representatives, and unless privileged, his attorney's. When answer is made by corporate defendant, state the name, address and title of persons supplying the information and making the affidavit, and announce the source of his or her information.
DEFINITIONS: 1
1.
The pronoun "you" refers to the party to whom the Interrogatories are addressed (the Defendant).
2.
"Identify" when referring to an individual, corporation, or other entity shall mean to set forth the name and telephone number, and if a corporation or other entity, its principle place of business, or if an individual, the present or last known home address, his or her job title or titles, by whom employed and address of the place of employment.
3.
“Accident” is defined as the accident that resulted in injury to the Plaintiff’s person which occurred on February 3rd, 2019 as referenced in the Plaintiff’s Complaint. INTERROGATORIES: PLEASE TAKE NOTICE that pursuant to Rule 33 of the North Carolina Rules of Civil Procedure, you are hereby requested to serve answers under oath and within thirty (30) days to the following interrogatories. These interrogatories shall be deemed to be continuing in nature and should the answers to any of these Interrogatories change prior to the time of trial, you shall give notice of all changes. 1.
State your full name and address and all aliases by which you have been known to any individual or any entity.
2.
State your date of birth, social security number, current mailing address, and physical address.
3.
State the name and address of your employer (if applicable), the contact information for your supervisor, your position and duties, and your wages at the time of the auto accident and at the present time.
4.
Please identify all persons (excluding attorneys) who investigated the cause and circumstances of this accident for you.
5.
Please identify all persons to whom you have given signed statements regarding the accident, the date thereof, and the name of the person in whose custody each is at this time.
6.
Please state whether you have within your possession or control photographs, plats, or diagrams of the scene of the auto accident or objects connected with said motor vehicle accident, stating what those objects are.
7.
State in detail your itinerary on the date of the accident, including each place at which you were present, your length of stay at each such place, and a detailed account of whom you saw and what you did at each such place.
8.
Please give a concise statement of facts as to how you contend the accident took place.
9.
Please state whether you consumed any drugs, medicines, or alcoholic beverages within twenty-four (24) hours prior to said occurrence, the place where such drugs, medicines, or alcoholic beverages were obtained, the nature of the drugs, medicines, or alcoholic beverages, and the amount thereof. 2
10.
Please state whether you were under the care of a physician at the time of the accident. If so, please state the name and address of your physician, specify the illness or condition for which you were treated, and list any prescribed medication.
11.
If you and the Plaintiff had any conversation after the accident, please state the substance of any such conversation.
12.
If any members of your family or anyone else had any conversations with the Plaintiff, please state to the best of your knowledge the place of such conversations and the nature of such conversations.
13.
Please state in detail all actions you took or attempted to take to avoid the accident.
This the 28th of March, 2019
____________________________
Kathryn A. Taylor Attorney for the Plaintiff 123 Main Street Gastonia, NC 28052 Telephone: (704) 285-0277 Telecopier: (704) 987-654
CERTIFICATE OF SERVICE
3
Certified on the 28th day of APRIL 2019, I have served a copy of the foregoing PLAINTIFFS FIRST SET OF INTERROGATORIES TO DEFENDANT by mailing via the United States Postal Service Certified Mail a copy thereof to the person or acceptable agent thereof hereinafter named below:
TO:
Michael Tumnus Defendant 1308 Winter Drive Narnia, NC 28021
________________________________ KATHRYN A. TAYLOR ATTORNEY FOR THE PLATINTIFF 123 MAIN STREET POST OFFICE BOX 1950 GASTONIA, NC 280521950 TELEPHONE: (704) 28050277 TELECOPIER: (704) 987654
4
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