Form 802

Court Rules

Rule 32 - Discovery

Rule 32.2.1 - Form 802

FORM 802

IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI

_________________________________

Plaintiff,

v. Case No.________________________

_________________________________

Defendant.

OPENING INTERROGATORIES TO INDIVIDUAL DEFENDANT
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/Chauffeur's License Number:________________________________

Issuing State:_____________________________________________________

RESIDENCE

2. State your present residence address and the period during which you have resided at said address:

Present Address:__________________________________________________

From _______________________________________________to present date.

MARRIAGE

3. Are you married at the present time? ( ) Yes ( ) No

If "Yes", state:

(a) Your spouse's first name and maiden name:_______________________________________

___________________________________________________________________________

CRIMES OR IMPRISONMENT

4. Have you ever pleaded guilty to or been convicted of a felony or misdemeanor? (This does not include municipal court convictions) ( ) Yes ( ) No

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FORM 802

If your answer is "Yes", state:

(a) The nature of the offense:______________________________________________________

___________________________________________________________________________

(b) The date and court:___________________________________________________________

___________________________________________________________________________

AGENCY

5. Were you at the time of the occurrence or occurrences forming the basis of this suit performing any job, task or undertaking for any person, firm or corporation other than yourself? ( ) Yes ( ) No

If your answer is "Yes", state:

(a) The name and address of the person, firm or corporation for whom you were performing some job, task, or undertaking?

________________________________________________________________________________________________________________________________________________________

(b) The nature of the job, task, or undertaking you were performing for such person, firm or corporation:

________________________________________________________________________________________________________________________________________________________

(d) Whether or not you were receiving any compensation from such other person, firm or corporation for the performance of the said job, task or undertaking:

________________________________________________________________________________________________________________________________________________________

DATE AND TIME

6. State the date and time of occurrence of the incident mentioned in plaintiff's petiti

on:

___________________________________________________________________________________

PLACE

7. State the exact location of the occurrence mentioned in plaintiff's petition, giving the name of the street or streets, road, alley or highway on which it occurred or the distances from other identifiable landmarks or points of reference:

______________________________________________________________________________________________________________________________________________________________________

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FORM 802

DISABILITY

8. Were you suffering from any physical disability or impairment at the time of the occurrence mentioned in plaintiff's petition? ( ) Yes ( ) No

If your answer is "Yes", explain:

______________________________________________________________________________________________________________________________________________________________________

STATEMENTS

9. Attach a copy of any recital or statement that you have from this party plaintiff, 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, plaintiff must advance fifty percent (50%) of the cost of same.

Do you have a statement: ( ) Yes ( ) No

Attached: ( ) Yes ( ) No

10. Please state what, if anything, plaintiff said to you or any other persons in your presence about the occurrence mentioned in plaintiff's petition concerning how the occurrence happened and what injuries plaintiff suffered:

______________________________________________________________________________________________________________________________________________________________________

WITNESSES

11. State the name 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 and Employment

___________________________________________________________________________________

(b) To have been present at the scene of the occurrence within thirty (30) minutes thereafter:

Name

Address and Employment

___________________________________________________________________________________

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FORM 802

________________________________________________________________________________________________________________________________________________________

PHOTOGRAPHS

12. 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 or preparation for litigation. ( ) Yes ( ) No

If your answer is "Yes", give the following:

Address of

Date Taken

Name of Photographer

Photographer

_____________________________________________________________________________________________________________________________________________________________________________________________________________________

ALCOHOL OR DRUGS

13. 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

INSURANCE

14. Do you have any insurance agreements which will indemnify you, in whole, or in part, against any judgment plaintiff may obtain in the instant action?

( ) Yes ( ) No

If your answer is "Yes", state:

(a) The name and address of the company or companies issuing such insurance agreements:

____________________________________________________________________________

(b) The policy number:____________________________________________________________

(c) The limits of Personal Injury, Property Damage and Medical Payments Coverage on the date of the occurrence mentioned in plaintiff's petition:

________________________________________________________________________________________________________________________________________________________

(d) Attach a copy of the Declaration Page or Certificate of Coverage of such policy of insurance to your answer to these interrogatories.

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FORM 802

PROPOSED ADDITIONAL STANDARD INTERROGATORIES:

15. Have any photographs, videotapes or motion pictures of plaintiff _______________________________

been taken by you or anyone acting on your behalf? If your answer is “yes,” please state for each:

(a) The date or dates each photograph, videotape or motion picture was taken;

(b) The name, address and job capacity of each person taking any such photograph, videotape or motion picture;

(c) The location where each photograph, videotape or motion picture was taken; and

(d) The present custodian(s) of the negatives of photographs and the original videotape or motion picture.

ANSWER:

16. As to each and every person whom you expect to call as an expert witness at trial, please state the following:

(a)

Full name and address, including street, city, state and zip code;

(b)

Occupation;

(c)

Place of employment;

(d)

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;

(e)

The general nature of the subject matter on which the expert is expected to testify, and

(f)

The expert’s hourly deposition fee.

ANSWER:

17. Please identify each non-retained expert witness, including defendant, whom you expect to call

trial who may provide expert witness opinion testimony. Please provide the expert’s name,

address and field of expertise.

ANSWER:

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Adopted 08/11/00
Effective 09/11/00

FORM 802

DEFENDANT'S SWORN SIGNATURE

STATE OF

)

) ss.

COUNTY OF

)

The below named person, being duly sworn on oath states that he or she read the foregoing interrogatories and the answers given are true to the best of affiant's knowledge and belief.

______________________________________

Signature of Party or Guardian

(NOT TO BE SIGNED BY ATTORNEY)

The foregoing answers to interrogatories were subscribed and sworn to before me this _______ date of _____________________________, 20_____.

___________________________________________

Notary Public

My Commission expires:

___________________________________

CERTIFICATES OF MAILING

The original and two (2) copies of the foregoing interrogatories were mailed to:

__________________________________________________________________________________________________________________________________________________________

This _______________ day of ______________________________, 20____.

___________________________________________

Attorney for Plaintiff

Original copy of the completed interrogatories mailed to the Department of Civil Records of the Circuit Court of Jackson County, Missouri and plaintiff's copy mailed to:

_____________________________________________________________________________

This _______________ day of ______________________________, 20_____.

___________________________________________

Attorney for Defendant

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Adopted 08/11/00
Effective 09/11/00