Professional Documents
Culture Documents
Pursuant to Rules 33, 34 and 36 of the Colorado Rules of Civil Procedure, you are to
answer the interrogatories hereinafter set forth, separately, full, in writing, and under
oath. You should deliver a true copy of your answer to the undersigned attorney within 30
DEFINITIONS
(a) INCIDENT includes the circumstances and events surrounding the alleged accident,
injury, or other occurrence or breach of contract giving rise to this action or proceeding.
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(b) YOU OR ANYONE ACTING ON YOUR BEHALF includes Sarah Robertson, Carol
and Kurt Robertson, your attorneys, and anyone else acting on your behalf.
(d) DOCUMENT means a writing, as defined in CRE 1001 and includes the original or a
them.
(e) HEALTH CARE PROVIDER includes any PERSON or entity referred to as a "Health
(f) ADDRESS means the street address, including the city, state, and zip code.
INSTRUCTIONS
A. You are required by Rule 33 of the Colorado Rules of Civil Procedure to answer fully and
factually each of the interrogatories hereinafter set out, furnish all information called for
by said interrogatory, sign your response, swear to your response and serve same upon
the undersigned attorney within thirty (30) days after the date of service of these
supplement your answers promptly if and when you obtain relevant information in
addition to, or in any way inconsistent with, your initial answer to any interrogatory.
C. If you object to, or otherwise decline to answer, any portion of an interrogatory, provide
all information called for in that portion of the interrogatory to which you do not object or
which you do not decline to answer. If you object to an interrogatory on the grounds that
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information as can be supplied without undertaking an undue burden. For those portions
of any interrogatory to which you object or otherwise decline to answer, state the reason
PATTERNED INTERROGATORIES
[] 1.1 State the name, ADDRESS, telephone number, and relationship to you of each
interrogatories. (Do not identify anyone who simply typed or reproduced the responses.)
[] 2.12 At the time of the INCIDENT, did you or any other person have any physical,
emotional, or mental disability or condition that may have contributed to the occurrence
of the INCIDENT?
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(c) The manner in which the disability or condition contributed to the occurrence
of the INCIDENT.
4.0 Insurance
[] 4.1 At the time of the INCIDENT, was there in effect any policy of insurance through
which you were or might be insured in any manner (for example, primary, pro-rata, or
excess liability coverage or medical expense coverage) for the damages, claims, or
(c) The name, ADDRESS, and telephone number of each named insured;
(e) The limits of coverage for each type of coverage contained in the policy;
(g) The name, ADDRESS, and telephone number of the custodian of the policy.
[] 6.1 Do you attribute any physical, mental, or emotional injuries to the INCIDENT.
[] 6.2 Identify each injury you attribute to the INCIDENT and the area of your body
affected.
[] 6.3 Do you still have any complaints that you attribute to the INCIDENT?
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(a) A description;
(b) Whether the complaint is subsiding, remaining the same, or becoming worse;
(c) The frequency and duration.
[] 6.4 Did you receive any consultation or examination (except from expert witnesses
covered by C.R.C.P. 35 or treatment from a HEALTH CARE PROVIDER for any injury
[] 6.5 Have you taken any medication, prescribed or not, as a result of injuries that you
[] 6.6 Are there any other medical services not previously listed (for example, ambulance,
nursing, prosthetics)?
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[] 6.7 Has any HEALTH CARE PROVIDER advised that you may require future or
additional treatment for any injuries that you attribute to the INCIDENT?
[] 10.1 At any time before the INCIDENT, did you have complaints or injuries that
involved the same part of your body claimed to have been injured in the INCIDENT?
(a) A description;
(c) The name, ADDRESS, and telephone number of each HEALTH CARE
[] 10.2 List all physical, mental, and emotional disabilities you had immediately before
the INCIDENT. (You may omit mental or emotional disabilities unless you attribute any
[] 10.3 At any time after the INCIDENT, did you sustain injuries of the kind for which
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(b) The name, ADDRESS, and telephone number of any other PERSON involved;
(d) The name, ADDRESS, and telephone number of each HEALTH CARE
[] 12.1 State the name, ADDRESS, and telephone number of each individual:
(a) Who witnessed the INCIDENT or the events occurring immediately before or
(c) Who heard any statements made about the INCIDENT by any individual at the
scene;
(a) The name, ADDRESS, and telephone number of the individual interviewed;
(c) The name, ADDRESS, and telephone number of the PERSON who conducted
the interview.
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(a) The name, ADDRESS, and telephone number of the individual from whom the
(b) The name, ADDRESS, and telephone number of the individual who obtained
the statement;
(d) The name, ADDRESS, and telephone number of each PERSON who has the
If so, state:
(d) The name, ADDRESS, and telephone number of the individual taking the
(e) The name, ADDRESS, and telephone number of each PERSON who has the
original or a copy.
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reproduction, or model of any place or thing (except for items developed by expert
(c) The name, ADDRESS, and telephone number of each PERSON who has it.
If so, state:
(a) The name, title, identification number, and employer of the PERSON who
(c) The name, ADDRESS, and telephone number of the PERSON for whom the
[] 17.1 Is your response to each request for admission served with these interrogatories an
unqualified admission?
(b) State all facts upon which you base your response;
(c) State the names, ADDRESSES, and telephone numbers of all PERSONS who
have
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(a) Identify all DOCUMENTS and other tangible things that support your
response and state the name, ADDRESS, and telephone number of the
NON-PATTERNED INTERROGATORIES
1.0 Describe with particularity what YOU were doing immediately before the dog bit
1.0 Produce all documents evidencing any physical, emotional, or mental disability or
might be insured in any manner for the damages, claims, or actions that have arisen
INCIDENT.
4.0 Produce all documents evidencing any continued physical, mental or emotional
a HEALTH CARE PROVIDER, for any injury you attribute to the INCIDENT.
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6.0 Produce all documents evidencing future or additional treatment for any injuries that
INCIDENT.
8.0 Produce any documents evidencing any complaints or injuries that involved the same
address.
14.0 Produce all documents that YOU OR ANYONE ACTING ON YOUR BEHALF
INCIDENT.
16.0 Produce any photographs, films, or videotapes depicting any place, object or
INCIDENT.
18.0 Produce all documents evidencing a report or reports made by any PERSON
1.0 Admit that the documents produced by YOU in response to Defendants First Set of
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2.0 Admit that all statements made in answer to all interrogatories listed herein are true
and authentic.
3.0 Admit that YOU obtained no permanent damage or injury, physical, emotional or
otherwise.
4.0 Admit that YOU pulled on the dogs tail while the dog was eating.
5.0 Admit that YOU were advised to not pull on the dogs tail.
6.0 Admit that YOU were advised to not ride the dog like a horse.
Harry Best
Trial Attorney for Defendant
Best, Simpleton & Alright
473 Court Street
Starville, Brockton 00011
555-555-4444
Attorney Registration # 00045825
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CERTIFICATE OF SERVICE
I certify that on April 21, 2016 a copy of the Defendants First Set of Interrogatories,
Request for Production and Request for Admissions to Plaintiffs was delivered to the
Signature:
Printed Name:
Address:
Telephone:
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