WEST PALM BEACH CAR ACCIDENT PLAINTIFFS’ INTERROGATORIES AND REQUEST TO ADMIT DIRECTED TO DEFENDANT REGARDING NOTICE OF NON-PARTY FAULT

NOW COME West Palm Beach Car Accident Plaintiffs, , by and through their attorneys, , and requests that the following Interrogatories, submitted under MCR 2.309, be answered by Defendants, under oath and that the answers be served upon the undersigned attorney for West Palm Beach Car Accident Plaintiff within twenty eight (28) days.
When used in these Interrogatories, the term “Defendant” or any synonym thereof is intended and shall embrace and include in addition to said Defendant, all agents, servants and employees, representatives, private investigators, or others who are in possession of or who may have obtained information for or on behalf of Defendant.
These Interrogatories are to be regarded as continuing and you are requested to provide, by way of supplementary answers thereof, such additional information as may hereafter be obtained by you or any person on your behalf which will augment or otherwise modify answers now given to these Interrogatories. Such supplemental responses are to be filed and served upon West Palm Beach Car Accident Plaintiffs with twenty eight (28) days after receipt of such information.
INTERROGATORIES
1. With regard to as to whom Defendant filed a Notice of Non-Party Fault, please provide the full name and address of this person/entity.
ANSWER
2. With regard to as to whom Defendant filed a Notice of Non-Party Fault, please provide each and every piece of tangible or physical evidence that you have to show that this person or entity was negligent in any way in contributing to the incident described in West Palm Beach Car Accident Plaintiffs’ Complaint.
ANSWER
3. With regard to as to whom Defendant filed a Notice of Non-Party Fault, please identify each and every person who will testify regarding the negligence as indicated in Defendant’s Notice of Non-Party Fault. Please provide their full name, address and telephone number.
ANSWER
4. With regard to as to whom Defendant filed a Notice of Non-Party Fault, please state whether this Defendant is in possession of any statements, photographs, diagrams or other evidence supporting the Notice of Non-Party Fault?
ANSWER
5. If the above answer to the immediately preceding Interrogatory is anything but in the negative, please provide details as to what Defendant has in his possession regarding same.
ANSWER
REQUEST TO ADMIT
1. Do you admit that Defendant is not aware of any people or persons who will testify in support of the Notice of Non-Party Fault filed in the above captioned matter by this Defendant.
RESPONSE
2. Please admit that this Defendant does not have any tangible evidence or any physical evidence to support the Notice of Non-Party Fault recently filed in the above cause of action by this Defendant.
RESPONSE
INTERROGATORY
1. If any of the above requests are anything but an absolute admission, please state the basis for said answer and include any documents or indicate any persons who you will use at the time of trial to prove said answer.
ANSWER