SHirchert-Interrogatories-Unit 6

SHirchert-Interrogatories-Unit 6 - AGAINST THE DRIVER IN...

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IN THE UNITES STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF ILLINOIS JUSTIN KING ) ) PLAINTIFF, ) VS ) CIVIL ACTION NO:_____________________ ) ANHEUSER BUSCH ) JUDGE: _____________________________ ) DEFENDANT ) INTERROGATORIES TO THE DEFENDANT Plaintiff, by and through his attorneys, Hirchert and Associates, requests that Defendant, Anheuser Busch, answer the following Interrogatories fully, under oath and in accordance with the Federal Rules of Civil Procedure, subject to the instructions set forth below: INSTRUCTIONS a. These Interrogatories are continuing in nature, and further supplementary answers may be requested prior to trial. b. Unless otherwise stated, these Interrogatories refer to the time, place and circumstances of the occurrence mentioned or complained of in Plaintiff’s Complaint. INTERROGATORIES 1. PLEASE PROVIDE A CURRENT PHYSICAL FOR THE DRIVER. 2. PLEASE PROVIDE A COMPLETE DRIVING HISTORY FOR THE DRIVER. 3. PLEASE PROVIDE ANY RECORDS OF DISIPLINARY ACTIONS TAKEN
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Unformatted text preview: AGAINST THE DRIVER, IN REGARDS TO HIS EMPLOYMENT WITH THE DEFANDANT COMPANY. 4. PLEASE HAVE DRIVER COMPLETE, IN HIS OWN WORDS, AND IN DETAIL HIS ACCOUNT OF THE ACCIDENT. 5. PLEASE PROVIDE A COPY OF YOUR COMPANY SAFTEY MANUAL. 6. PLEASE PROVIDE A DETAILED DESCRIPTION OF THE COMPANY’S REQUIREMENTS FOR LOAD SECUREMENT. 7. PLEASE PROVIDE THE MAINTENANCE RECORDS FOR SAID VEHICLE. 8. PLEASE PROVIDE THE DRIVERS SCHEDULE ON THE DAY OF THE ACCIDENT, AS WELL AS A STATEMENT AS TO IF THE DRIVER WAS BEHIND SCHEDULE THE DAY OF THE ACCIDENT. 9. WAS DRIVER TESTED FOR IMPAIRMENT FOLLOWING THE ACCIDENT? 10. WHAT IS YOUR COMPANY POLICY REGARDING EMPLOYEE ACCIDENTS, AND DRUG/ALCOHOL TESTING FOLLOWING AN ACCIDENT? Respectfully submitted, The Law Offices of Hirchert and Associates BY: Shellie Hirchert Shellie Hirchert ABA# 1189357 1234 Main Street Monrovia, IN 46158 555-555-5555...
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  • Spring '12
  • Multiple
  • Complaint, Pleading, BUSCH _____________________________ DEFENDANT, following Interrogatories, Hirchert and Associates

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