1 Siddharth Navaneetha Raj

39005 Lochmoor Dr
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Solon, OH 44139
3 7657147243 | Fax
siddun11@gmail.com
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COURT OF COMMON PLEAS
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CUYAHOGA COUNTY

7 LOGAN LOVELL, Case No.: 123456789

8 Plaintiff,
9 PLEADING TITLE
vs.
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PAT SAINSBURY,
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Defendant
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PLAINTIFF’S INTERROGATORIES
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Plaintiff, through his counsel, Siddharth Navaneetha Raj, requests that the

18 Defendant respond to the following interrogatories. You are required to answer these
19 interrogatories separately and fully in writing, under oath. You are required to respond to these
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interrogatories no later than thirty (30) calendar days after receipt of these interrogatories, to the
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undersigned at 39005 Lochmoor Dr, Solon OH 44139.
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24 1. State your full name, home address (and all addresses for the last five (5)

25 years, social security number, date of birth, marital status and your employer's
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name and address. Include in your answer who was lived with you in the five
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(5) year period before the accident.
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DEFENDANT'S NAME - 1
 1 2. If you contend that the personal injuries of Plaintiff were not caused by the
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collision with your vehicle, state with particularity the facts upon which you
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base your contention.
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3. State the name and address of your employer, your position and duties, and
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6 your wages at the time of the auto accident and at the present time.

7 4. Identify all persons answering or supplying information used in answering

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these Interrogatories.
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5. State the name, address, and business telephone number of each person with
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personal knowledge regarding the facts and circumstances surrounding the
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12 happenings of the occurrences referred to in the complaint.

13 6. State whether you possess or control photographs or diagrams of the scene of

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the accident or objects connected with said motor vehicle accident, and state
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what those objects are.
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7. If at the time of the alleged accident, you possessed a valid license to operate a
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18 motor vehicle, state:

19 a. The State issuing it;

20 b. The issuance and expiration date;
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c. The license number;
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d. The nature of any restrictions on said license.
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8. Identify your applicable motor vehicle insurance carrier at the time of the

25 accident.
26 9. Describe the damages and fines incurred by the motor vehicle accident.
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10. Describe, in your own words, how the accident occurred.
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DEFENDANT'S NAME - 2
 1 11. In the 24 hours prior to the accident, had you consumed any drugs, medicines,
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or alcoholic beverages? If so, please list the type, amount, and time consumed.
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12. Provide the year, make, model, and identify the current registered owner of
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the vehicle driven at the time of the accident.
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6 13. How fast were you going at the time of the accident?

7 14. Were you using a cellphone within five (5) minutes of the alleged accident?
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15. Within the past 10 years, have you been involved (as a driver) in any other
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automobile accidents? If applicable, provide the date, nature of the accident,
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and any related legal outcome.
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12 16. Explain in detail your itinerary on the date of the auto accident, including each

13 place at which you were present, your length of stay at each such place, and a
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detailed account of who you saw and what you did at each place.
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17. Identify all persons known to you to have personal knowledge of the facts
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pertaining to the occurrence, and indicate those who were eyewitnesses, and
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18 state the substance of their knowledge and articulate their expected testimony.

19 18. Identify all persons (excluding attorneys) who investigated the cause and
20 circumstances of this personal injury auto accident for you.
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19. Identify all persons who arrived at the scene of the auto accident within one
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(1) hour after the auto accident.
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20. Identify all persons to whom you have given signed statements regarding the

25 auto accident, the date thereof, and the name of the person in whose custody
26 each is at this time.
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DEFENDANT'S NAME - 3
 1 21. Identify all persons who have given you signed statements regarding the
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accident, or the personal injuries suffered by the Plaintiff in the accident.
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22. If you believe that the Plaintiff acted in such a manner as to cause or
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contribute to his personal injuries, state all facts upon which you rely to
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6 demonstrate this.

7 23. Identify all expert witnesses who will be called at the trial, their areas of
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expertise, and summaries of their expected testimonies.
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24. Were you under the care of a physician at the time of the accident? If so, state
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the name and address of said physician, and specify the illness or condition as
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12 well as any prescribed medication.

13 25. List all violations of the motor vehicle laws of the State of Ohio or any other
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jurisdiction you have been charged with since obtaining your driver’s license.
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26. Which part of your vehicle came into contact with which part of the Plaintiff’s
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vehicle?
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18 27. If you had a conversation with the Plaintiff after the accident, provide a

19 summary of the conversation.

20 28. Demonstrate all actions you took or attempted to take to avoid the accident.
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29. Identify all persons driving with you in your vehicle during the day of the
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accident, and their current addresses and phone numbers.
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30. If any family members or anyone you know had conversations with the

25 Plaintiff, state the location and nature of these conversations.

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Dated this 2nd day of April, 2020.
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DEFENDANT'S NAME - 4
 1 Saul Goodman
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DEFENDANT'S NAME - 5