Rule 32 - Discovery
Rule 32.2.1 - Form 801
FORM 801
OPENING INTERROGATORIES TO PLAINTIFF IN
VEHICULAR NEGLIGENCE PERSONAL INJURY OR
PROPERTY DAMAGE CASES ONLY
NAME
1. State your full name, date of birth and place of birth:
Name: _________________________________________________________
Date of Birth: ___________________________________________________
Place of Birth: ___________________________________________________
Operator's or Chauffeur's License No.: ________________________________
RESIDENCE
2. State your present residence address and the period during which you have resided at said address:
Present Address:__________________________________________________
From ____________________________________ to present date.
3. List all other addresses at which you have resided during the past five years and the date of the use of each.
Prior Addresses From Date of To Date Of
___________________________________ _______________ ____________
___________________________________ _______________ ____________
MARRIAGE
4. Were you married at the time of the occurrence? ( ) Yes ( ) No
If "Yes" state:
(a) That spouse's full name, maiden name, and present address:
________________________________________________________________
________________________________________________________________
(b) Number of previous marriages:_________________________________
EMPLOYMENT
In the event you are claiming personal injury, please answer this Interrogatory:
5. For each of your employers during the past five years state: (Please use the schedule below)
(a) The name and address of each employer;
(b) The date of commencement and termination of employment;
(c) The title of the position which you held and the nature of the work being performed.
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(a) (b) (c)
Commencement &
Employer & Address Termination Title & Nature
1.__________________________________ _______________ ____________
2.__________________________________ _______________ ____________
3.__________________________________ _______________ ____________
In the event you are claiming personal injury, please answer this Interrogatory:
6. Have you lost any time from any employment since the occurrence referred to in the petition? ( ) Yes ( ) No
If your answer is "Yes", state:
(a) The cause of such loss of time: ________________________________
________________________________________________________________
________________________________________________________________
(b) The number of days lost and the dates:
Days Lost Dates
____________________________________________________ ____________
____________________________________________________ ____________
____________________________________________________ ____________
INCOME AND TAX RETURNS
7. If you claim loss of income as a result of the occurrence described in your petition, answer the following:
(a) State amount of claimed lost income:____________________________
b) Explain how amount is computed:_______________________________
__________________________________________________________
(c) Your yearly gross income for the three years prior to the year of this occurrence (1, 2, 3 below), the year of the occurrence (4 below) and all subsequent years (5 and 6 below):
Year Amount
1. __________________ ___________________________________
2. __________________ ___________________________________
3. __________________ ___________________________________
4. __________________ ___________________________________
5. __________________ ___________________________________
6. __________________ ___________________________________
(d) Attach copies of federal tax returns for the above years or sign the attached authorization to obtain copies of tax returns, copies of which will be furnished to your attorney.
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8. Itemize any special damages other than lost earnings which you claim:
Doctor Bills:_____________________________________________________________
_______________________________________________________________________
_______________________________________________________________________
_______________________________________________________________________
Hospital Bills:____________________________________________________________
_______________________________________________________________________
_______________________________________________________________________
Drugs:_________________________________________________________________
_______________________________________________________________________
Total Property Damage, whether or not claimed:________________________________
_______________________________________________________________________
Property Damage claimed in this action:_______________________________________
_______________________________________________________________________
Has there been any assignment, loan receipt or subrogation receipt signed by you or anyone acting on your behalf? ( ) Yes ( ) No
Attach copies of all repair bills and repair estimates in your possession to your answers to these interrogatories.
Other Special Damages:_____________________________________________ _______________________________________________________________________
In the event you are claiming personal injury, please answer this Interrogatory:
9. (a) What parts of your body were injured as a result of the occurrence referred to in the Petition?
(b) State the parts of your body referred to in (a) above of which you presently complain:__________________________________________
__________________________________________________________
In the event you are claiming personal injury, please answer this Interrogatory:
10. With respect to the injuries claimed, state:
(a) The names and approximate number of treatments by all doctors treating or examining you for the injuries; or attach itemized copies of statements from such doctors:
Name of Doctor Address of Doctor of Visits
___________________________ __________________ _____________
___________________________ __________________ _____________
___________________________ __________________ _____________
(b) Have you been hospitalized for such injuries, and if so, when and where?
PRIOR OR SUBSEQUENT INJURIES
In the event you are claiming personal injury, please answer this Interrogatory:
11. Except for this lawsuit, have you within the last ten (10) years made claim or filed suit for damages or compensation for personal injuries: ( ) Yes ( ) No
If your answer is "Yes", state:
Date of injury as shown in Interrogatory No. 11:
Name of your attorney, if you had one:__________________________________
Name of Party Against Whom Made Address
________________________________________________________________
________________________________________________________________
________________________________________________________________
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Name of other party's insurer:_________________________________________
Court or agency where claim or suit filed, if any:__________________________
________________________________________________________________
(b) Add separate page for all other claims, giving all information required above.
12. If you will without an Order, sign the attached medical authorization which should be attached to the service copy of your answers to these interrogatories.
WITNESSES
13. State the names and present or last known addresses and employment of all persons known to you or reported to you, your agents, attorneys, or others acting on your behalf:
(a) To have witnessed the occurrence mentioned in the pleadings:
Name Address & Employment
________________________________________________________________
________________________________________________________________
________________________________________________________________
(b) To have been present at the scene of the occurrence within thirty (30) minutes thereafter:
Name Address & Employment
________________________________________________________________
________________________________________________________________
________________________________________________________________
STATEMENT
14. (a) Attach a copy of any recital or statement that you have from this party, if an individual, whether it be in writing, reduced to writing, steno type, recorded or otherwise. (If these interrogatories are served on behalf of more than one party, answer as to each.) In the case of a court reporter's transcript, defendant must advance fifty (50%) percent of the cost of same.
Do you have a statement: ( ) Yes ( ) No
Attached: ( ) Yes ( ) No
- State what, if anything, defendant said to you or any other persons in your presence about the occurrence mentioned in plaintiff's Petition concerning how the occurrence happened.
15. Did you consume any alcoholic beverage of any type, or any sedative, tranquilizer or other drug, medicine or pill during the twelve (12) hours immediately preceding the occurrence referred to in the Petition? ( ) Yes ( ) No
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SERVICE IN ARMED FORCES
In the event you are claiming personal injury, please answer this Interrogatory:
16. Have you ever served in the Armed Forces? ( ) Yes ( ) No
If your answer is "Yes", state:
(a) The particular branch for whom you performed services:
Branch and Serial Number if known:_____________________________
(b) If you were ever rejected or discharged for medical reasons, state:
( ) Yes ( ) No
In the event you are claiming personal injury, please answer this Interrogatory:
17. Have you ever received benefits from the Veterans Administration for injury or disability? ( ) Yes ( ) No
If "Yes", state your V.A. claim number and nature of disability or injury.
Disability or Injury Claim Number
_______________________________________________________________________
_______________________________________________________________________
_______________________________________________________________________
SOCIAL SECURITY AND DISABILITY BENEFITS
In the event you are claiming personal injury, please answer this Interrogatory:
18. Are you now receiving or have you ever received any disability benefits, from any source: ( ) Yes ( ) No
Source:__________________________________________________________
CRIMES OR IMPRISONMENT
19. Have you ever pleaded guilty to or been convicted of a felony or misdemeanor? (This does not include municipal court convictions) ( ) Yes ( ) No
If your answer is "Yes", state:
(a) The nature of the offense:_____________________________________
__________________________________________________________
(b) The date and court:__________________________________________
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PHOTOGRAPHS
20. State whether any photographs were made at the scene of the occurrence or of any vehicles involved by anyone other than you, your attorney or agent in anticipation of preparation for litigation. ( ) Yes ( ) No
If yes, give the following: Address of
Date Taken Name of Photographer Photographer
____________ ___________________________________________________
____________ ___________________________________________________
____________ ___________________________________________________
PROPOSED ADDITIONAL STANDARD INTERROGATORIES
21. As to each and every person whom you expect to call as an expert witness at trial, please state the following:
- Full name and address, including street, city, state and zip code;
- Occupation;
- Place of employment;
- Qualifications to give an opinion, or if such is available on the expert’s curriculum vitae, such curriculum vitae may be attached to these interrogatory answers;
- The general nature of the subject matter on which the expert is expected to testify; and
- The expert’s hourly deposition fee.
ANSWER:
22. Please identify each non-retained expert witness, including plaintiff, whom you expect to call at trial who may provide expert witness opinion testimony. Please provide the expert’s name, address and field of expertise.
ANSWER:
23. Pursuant to §509.050 R.S.Mo. as amended (1987), please state the total amount of monetary damages you are claiming.
ANSWER:
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PLAINTIFF'S SWORN SIGNATURE
STATE OF )
) ss.
COUNTY OF )
The below named person, being duly sworn on oath states that he or she has read the foregoing interrogatories and the answers given are true to the best of affiant's knowledge and belief.
_________________________________________
Signature of Party or Next Friend
(NOT TO BE SIGNED BY ATTORNEY)
The foregoing answers to interrogatories were subscribed and sworn to before me on this __________ day of _________________, 20____.
_________________________________________
Notary Public
My commission expires:
__________________________
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CERTIFICATES OF MAILING
The original and two (2) copies of the foregoing interrogatories were mailed to:
_______________________________________________________________________________________________________________________________________________________________________________________________________________________________________
This ______ day of ________________, 20 ____.
_____________________________________________
Attorney for Defendant
Original copy of the completed interrogatories mailed to the Department of Judicial Records of the Circuit Court of Jackson County, Missouri and defendant's copy mailed to:
_____________________________________________________________________________
This ______ day of ________________, 20 ____.
_____________________________________________
Attorney for Plaintiff
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Adopted 8/21/09 Effective 9/21/09