Advanced Civil Lit Four.doc.docx

CAUSE NO. 342-268256-13

JANET STROTHER, § IN THE DISTRICT COURT OFPlaintiff, §

§VS. § HARRIS COUNTY, OHIO

§SUSAN FRIED, §

Defendant. § 342ND JUDICIAL DISTRICT______________________________________________________________________________

NOTICE OF ORAL DEPOSITION OF SUSAN FRIED______________________________________________________________________________

TO: Susan Fried, by and through its attorneys of record, Vincent P. Circelli, Cicelli &Young, PLLC, 500 East 4th Street, Suite 250, University Village, Ohio 77663.

PLEASE TAKE NOTICE that, pursuant to Rule 30 of the Ohio Rules of Civil Procedure,

the undersigned will take the deposition upon oral examination of Susan Fried. The

deposition will begin at 10:00am on Monday, August 12, 2013 at the office of Attorney

Teanna Neskora, 1980 Post Oak Blvd., Suite 1800, University Heights, Ohio 77663.

Said deposition shall continue from day-to-day until completion, shall be recorded by

sound or stenographic means and shall be before a Notary Public or other individual

qualified to administer oaths.

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Respectfully submitted,

GORDON, ARATA, MCCOLLAM,DUPLANTIS & EAGAN, LLC

By:Charles L. StinnefordState Bar No. 007850571980 Post Oak Boulevard, Suite 1800University Heights, Ohio 77663(713) 333-5500 Telephone(713) 333-5501 [email protected]

Attorneys for Plaintiff

CERTIFICATE OF SERVICE

I, the undersigned, certify that I am a member of the firm of Gordon, Arata, McCollam,

Duplantis & Eagan, LLC, attorneys for Defendant and Counter-Plaintiff, Buxton Company, and

that a true and correct copy of the foregoing has been sent to all counsel of record on this 20th

day of November, 2014.

Mr. Vincent P. Circelli Via CM/RRR #_____________________________Circelli & Young, PLLC500 East 4th Street, Suite 250University Heights, Ohio 77663

Charles L. Stinneford

AO 88A (Rev. 02/14) Subpoena to Testify at a Deposition in a Civil Action

UNITED STATES DISTRICT COURTfor the

__________ District of __________

))))))

Plaintiff

v. Civil Action No.

Defendant

SUBPOENA TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION

To:

(Name of person to whom this subpoena is directed)

’ Testimony: YOU ARE COMMANDED to appear at the time, date, and place set forth below to testify at a deposition to be taken in this civil action. If you are an organization, you must designate one or more officers, directors,or managing agents, or designate other persons who consent to testify on your behalf about the following matters, orthose set forth in an attachment:

Place: Date and Time:

The deposition will be recorded by this method:

’ Production: You, or your representatives, must also bring with you to the deposition the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of thematerial:

The following provisions of Fed. R. Civ. P. 45 are attached – Rule 45(c), relating to the place of compliance;Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty torespond to this subpoena and the potential consequences of not doing so.

Date:CLERK OF COURT

OR

Signature of Clerk or Deputy Clerk Attorney’s signature

The name, address, e-mail address, and telephone number of the attorney representing (name of party)

, who issues or requests this subpoena, are:

Notice to the person who issues or requests this subpoenaIf this subpoena commands the production of documents, electronically stored information, or tangible things beforetrial, a notice and a copy of the subpoena must be served on each party in this case before it is served on the person towhom it is directed. Fed. R. Civ. P. 45(a)(4).

AO 88A (Rev. 02/14) Subpoena to Testify at a Deposition in a Civil Action (Page 2)

Civil Action No.

PROOF OF SERVICE

(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)

I received this subpoena for (name of individual and title, if any)

on (date) .

’ I served the subpoena by delivering a copy to the named individual as follows:

on (date) ; or

’ I returned the subpoena unexecuted because:

.

Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have alsotendered to the witness the fees for one day’s attendance, and the mileage allowed by law, in the amount of

$ .

My fees are $ for travel and $ for services, for a total of $ .

I declare under penalty of perjury that this information is true.

Date:Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc.:

AO 88A (Rev. 02/14) Subpoena to Testify at a Deposition in a Civil Action (Page 3)

Federal Rule of Civil Procedure 45 (c), (d), (e), and (g) (Effective 12/1/13)

(c) Place of Compliance.

(1) For a Trial, Hearing, or Deposition. A subpoena may command aperson to attend a trial, hearing, or deposition only as follows: (A) within 100 miles of where the person resides, is employed, orregularly transacts business in person; or (B) within the state where the person resides, is employed, or regularlytransacts business in person, if the person (i) is a party or a party’s officer; or (ii) is commanded to attend a trial and would not incur substantialexpense.

(2) For Other Discovery. A subpoena may command: (A) production of documents, electronically stored information, ortangible things at a place within 100 miles of where the person resides, isemployed, or regularly transacts business in person; and (B) inspection of premises at the premises to be inspected.

(d) Protecting a Person Subject to a Subpoena; Enforcement.

(1) Avoiding Undue Burden or Expense; Sanctions. A party or attorneyresponsible for issuing and serving a subpoena must take reasonable stepsto avoid imposing undue burden or expense on a person subject to thesubpoena. The court for the district where compliance is required mustenforce this duty and impose an appropriate sanction—which may includelost earnings and reasonable attorney’s fees—on a party or attorney whofails to comply.

(2) Command to Produce Materials or Permit Inspection. (A) Appearance Not Required. A person commanded to producedocuments, electronically stored information, or tangible things, or topermit the inspection of premises, need not appear in person at the place ofproduction or inspection unless also commanded to appear for a deposition,hearing, or trial. (B) Objections. A person commanded to produce documents or tangiblethings or to permit inspection may serve on the party or attorney designatedin the subpoena a written objection to inspecting, copying, testing, orsampling any or all of the materials or to inspecting the premises—or toproducing electronically stored information in the form or forms requested.The objection must be served before the earlier of the time specified forcompliance or 14 days after the subpoena is served. If an objection is made,the following rules apply: (i) At any time, on notice to the commanded person, the serving partymay move the court for the district where compliance is required for anorder compelling production or inspection. (ii) These acts may be required only as directed in the order, and theorder must protect a person who is neither a party nor a party’s officer fromsignificant expense resulting from compliance.

(3) Quashing or Modifying a Subpoena.

(A) When Required. On timely motion, the court for the district wherecompliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply; (ii) requires a person to comply beyond the geographical limitsspecified in Rule 45(c); (iii) requires disclosure of privileged or other protected matter, if noexception or waiver applies; or (iv) subjects a person to undue burden. (B) When Permitted. To protect a person subject to or affected by asubpoena, the court for the district where compliance is required may, onmotion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development,or commercial information; or (ii) disclosing an unretained expert’s opinion or information that doesnot describe specific occurrences in dispute and results from the expert’sstudy that was not requested by a party. (C) Specifying Conditions as an Alternative. In the circumstancesdescribed in Rule 45(d)(3)(B), the court may, instead of quashing ormodifying a subpoena, order appearance or production under specifiedconditions if the serving party: (i) shows a substantial need for the testimony or material that cannot beotherwise met without undue hardship; and (ii) ensures that the subpoenaed person will be reasonably compensated.

(e) Duties in Responding to a Subpoena.

(1) Producing Documents or Electronically Stored Information. Theseprocedures apply to producing documents or electronically storedinformation: (A) Documents. A person responding to a subpoena to produce documentsmust produce them as they are kept in the ordinary course of business ormust organize and label them to correspond to the categories in the demand. (B) Form for Producing Electronically Stored Information Not Specified.If a subpoena does not specify a form for producing electronically storedinformation, the person responding must produce it in a form or forms inwhich it is ordinarily maintained or in a reasonably usable form or forms. (C) Electronically Stored Information Produced in Only One Form. Theperson responding need not produce the same electronically storedinformation in more than one form. (D) Inaccessible Electronically Stored Information. The personresponding need not provide discovery of electronically stored informationfrom sources that the person identifies as not reasonably accessible becauseof undue burden or cost. On motion to compel discovery or for a protectiveorder, the person responding must show that the information is notreasonably accessible because of undue burden or cost. If that showing ismade, the court may nonetheless order discovery from such sources if therequesting party shows good cause, considering the limitations of Rule26(b)(2)(C). The court may specify conditions for the discovery.

(2) Claiming Privilege or Protection. (A) Information Withheld. A person withholding subpoenaed informationunder a claim that it is privileged or subject to protection as trial-preparationmaterial must: (i) expressly make the claim; and (ii) describe the nature of the withheld documents, communications, ortangible things in a manner that, without revealing information itselfprivileged or protected, will enable the parties to assess the claim. (B) Information Produced. If information produced in response to asubpoena is subject to a claim of privilege or of protection astrial-preparation material, the person making the claim may notify any partythat received the information of the claim and the basis for it. After beingnotified, a party must promptly return, sequester, or destroy the specifiedinformation and any copies it has; must not use or disclose the informationuntil the claim is resolved; must take reasonable steps to retrieve theinformation if the party disclosed it before being notified; and may promptlypresent the information under seal to the court for the district wherecompliance is required for a determination of the claim. The person whoproduced the information must preserve the information until the claim isresolved.

(g) Contempt.The court for the district where compliance is required—and also, after amotion is transferred, the issuing court—may hold in contempt a personwho, having been served, fails without adequate excuse to obey thesubpoena or an order related to it.

For access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013).

CAUSE NO. 342-268256-13



§SUSAN FRIED, §


PLAINTIFF’S REQUEST FOR PRODUCTION______________________________________________________________________________

TO: Susan Fried, by and through her attorneys of record, Mr. Thomas J. Williams, Mr.Vincent P. Circelli, Mr. William Patterson, Haynes and Boone, LLP, 201 Main Street,Suite 2200, University Heights, Ohio 77663.

COMES NOW, PLAINTIFF, Janet Strother “Strother” and serves the following First

Request for Production on Susan Fried “Fried,” pursuant to Ohio Rule of Civil Procedure 196.

Susan Fried is notified that she must produce all requested documents for inspection and copying

either as they are kept in the ordinary course of business or segregated according to each request.

The documents must be produced within 30 days of service of this request at the law offices of

Gordon Arata McCollam Duplantis & Eagan, LLP, 1980 Post Oak Boulevard, Suite 1800,

University Heights, Ohio 77663.

Plaintiff(s) Request for Productionof Documents Directed to Defendant(s)

You are requested to produce, in accordance with Ohio Rule of Civil Procedure 4009, the

originals or clear, readable copies of the below listed documents and/or items. These documents

and/or items will be examined and/or photocopied; photograph negatives will be processed and

photographs reproduced, videotapes and audiotapes shall be viewed and/or heard and a copy

made. The below listed documents and/or items are to be produced at Plaintiff’s counsel’s office

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on or before thirty (30) days from the date of service herein. Such request is continuing up to and

at the time of trial.

DEFINITIONS

A. "You" or "your" refers to Defendant(s) herein and to all other persons acting or

purporting to act on behalf of Defendant(s), including agents and employees.

B. "Communications" shall mean all inquiries, discussions, conversations, negotiations,

agreements, understandings, meetings, telephone conversations, letters, correspondence, notes,

telegrams, telexes, advertisements, facsimiles, e-mail, or other forms of verbal and/or

communicative intercourse.

C. "Documents" shall mean all written or graphic matter of every kind or description,

however, produced or reproduced, whether draft or final, original or reproduction signed or

unsigned, and regardless of whether approved, signed, sent, received, redrafted, or executed,

including but not limited to: written communications, letters, correspondence, facsimiles, e-mail,

memoranda, minutes, notes, films, recordings, of any type, transcripts, contracts, agreements,

purchase or sales orders, memoranda of telephone conversations of personal conversations,

diaries, desk calendars, interoffice communications, reports, studies, bills, receipts, checks,

checkbooks, invoices, requisitions or material similar to any of the foregoing however

denominated, by whomever prepared, and to whomever addressed, which are in your possession,

custody or control or to which you have had or can obtain access.

D. "Persons" means an individual, corporation, partnership, trust, associations, company,

organization, or any form of a business or commercial entity.

E. "Identify" when used with respect to an individual, means to state (1) their name; (2)

business affiliation and official title and/or position; and (3) their last known residential and

business address.

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F. "Identify" when used with respect to a document, means to state (1) the type of document

(e.g. letter, memorandum, hand-written note, facsimile, e-mail); (2) its date of origin or creation;

(3) its author and addressee; (4) its last known custodian or locations; and (5) a brief description

of its subject matter and size. In lieu of identifying any document(s), you may attach a copy of it

to your answer, indicating the question to which it is responsive.

G. "Identify" when used with respect to a company or other business entity, means to state,

(1) the company's legal name, any former names, and the name under which it trades or does

business (2) the address of its principal place of business; and (3) the identity of its chief

executive officer.

H. "Relate to" means consist of, refer to, reflect or be in any way logically connected with

the matter discussed.

I. The period of time encompassed by these requests shall be from the date of the alleged

accident to the date of answering, unless otherwise indicated. Note, this request is continuing up

to and at the time of trial.

J. For purposes of the Rule, a statement includes:

(1) A written statement, signed or otherwise adopted or approved by the person

making it, or

(2) A stenographic, mechanical, electronic, videographic or other recording, or a

transcript thereof, which is a substantially verbatim recital of an oral statement by the

person making it and contemporaneously recorded.

REQUESTS

1. The entire claims and investigation file or files including but not limited to daily activity

sheets, diary sheets, and status sheets of any insurance adjuster and/or risk employee/manager,

internal memoranda regarding this claim created, sent and/or received by any insurance adjuster

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or other adjuster, risk employee/manager and/or by the Defendant(s) or an agent/employee of the

Defendant(s), communications to and from all insurance carriers, parties, Defendant(s), or

potential parties, request(s) for investigation, and/or reports/findings of investigators, both in-

house and/or independent and/or all insurance policies of the Defendant(s), excluding references

to mental impressions, conclusions, or opinions representing the value or merit of the claim or

defense or respecting strategy or tactics and privileged communications from counsel.

2. All statements and communications of any and all witnesses including any and all

statements of Plaintiff(s) and Defendant(s), including taped recordings, whether transcribed or

not, as well as all written statements.

3. Any and all documents and communications containing the name, home and business

address and qualifications of all persons who have been retained or specially employed by

Defendant(s) in anticipation of litigation or preparation for trial and who are not expected to be

called as witnesses at trial or as to whom no such decision has yet been made, and attach any

documents or communications received from said person(s). If there are no documents or

communications, then the name of said person(s) as well as their home and business addresses

should be provided.

4. The name, home and business address of the insurance carrier investigators employed by

the Defendant(s) or its insurance carrier to investigate this claim, treatment of the Plaintiff(s),

witnesses, or any other aspect of the incidents that form the basis of Plaintiff(s) Complaint. Also,

attach any documents, records or communications of or prepared by the investigator acquired as

a result of their investigation(s), including but not limited to telephone calls, correspondence,

facsimiles, e-mail, billing, inspections or observations, interviews, statements and/or findings.

5. The name, home and business address, background and qualifications of any and all

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persons in the employ of Defendant(s), who in anticipation and/or preparation of litigation, is

expected to be called to trial.

6. Any and all documents and communications containing the name and home and business

addresses of all individuals contacted as potential witnesses.

7. Reports, communications, and/or documents prepared by any and all experts who will

testify at trial.

8. Reports, manuals, textbooks, policy sheets or other documents, or communications which

any said expert, potential expert, witness or potential witness has consulted or reviewed as a

result or in preparation of this litigation or will consult or review.

9. Resumes and qualifications of any and all experts who will testify at trial.

10. Copies of any and all photographs, diagrams, drawings, charts, models, movie films or

video-tapes which relate, refer or pertain to Plaintiff(s), any other party to this action, the

incident site and/or any instrumentality involved in the incident described in Plaintiff(s)

Complaint.

11. Any and all documents and communications substantiating any defense to Plaintiff's

cause of action.

12. Copies of any and all reports and records prepared by any physician, hospital or

healthcare provider who has examined Plaintiff(s) excluding those actually provided by counsel

for Plaintiff.

13. Central indexing information on Plaintiff(s), and any and all Defendant(s) or employees

of the Defendant(s) for this alleged accident, alleged prior accident(s), and alleged subsequent

accident(s).

14. Verification of the policy limits for liability benefits, medical payments and any “umbrella”

or excess benefits, including a copy of the policy, including applicable policy declarations page.

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15. Copies of internal memoranda, inter-office memos, facsimiles, e-mail or other documents

or communications regarding this claim, made by the Defendant(s) and/or any agent and/or

employee of Defendant(s), or their insurance carrier(s).

16. Any and all reports, communications and/or documents prepared by Defendant(s) or their

employee(s)/agent(s) containing the facts, circumstances and causes of this alleged accident.

17. The name and address of the manager of Defendant's claim office located at the place

where Plaintiff(s) medical bills and reports were submitted to.

18. Any and all documents of any nature whatsoever which refer in any way to the incident

described in Plaintiff(s) Complaint and/or the facts or circumstances leading up to and following

said incident.

19. All property damage estimates rendered for any object belonging to the Plaintiff(s) and/or

Defendant(s) which was involved in this alleged accident.

20. Any and all press releases concerning this alleged accident or any incident relating to this

lawsuit.

21. Any and all documents or other tangible materials of any nature whatsoever which you

plan to have marked for identification at a deposition or trial, introduce into evidence at a

deposition or trial, or about which you plan to question a witness at a deposition or trial.

22. Any and/or all documents or communications of any nature whatsoever which relate,

refer or pertain to Plaintiff(s), any other party to this action, the incident, incident site and/or any

instrumentality involved in the incident described in Plaintiff(s) Complaint.

23. All documents and/or communications relating to any facts on the basis of which it is

asserted that the conduct of the Plaintiff(s) contributed to the happenings of the alleged

occurrence or to the alleged injuries or losses suffered allegedly as a result of this accident.

24. Any and all documents of any nature whatsoever referred to in Defendant’s(s’) Answers

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to Plaintiff’s(s’) Interrogatories.

This request is deemed to be continuing insofar as if any of the above is secured subsequent to

the date herein for the production of same, said documents, photographs, statements, reports,

etc., are to be provided to Plaintiff's counsel within thirty (30) days of receipt of same.



/s/ Charles L. StinnefordCharles L. StinnefordState Bar No. 007850571980 Post Oak BoulevardSuite 1800University Heights, Ohio 77663(713) 333-5500 Telephone(713) 333-5501 [email protected]


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Duplantis & Eagan, LLC, attorneys for Plaintiff, and that a true and correct copy of the foregoing

has been sent to all counsel of record on this ___ day of _______, 20__.

Mr. Thomas J. Williams Via CM/RRR #_____________________________Mr. Vincent P. CircelliMr. William Travis PattersonHaynes and Boone, LLP201 Main Street, Suite 2200University Heights, Ohio 77663817-347-6600817-347-6650 FAX

/s/ Charles L. StinnefordCharles L. Stinneford

CAUSE NO. 342-268256-13



§SUSAN FRIED, §


PLAINTIFF’S INTERROGATORIES TOTHE DEFENDANT

_____________________________________________________________________________

TO: The Starr Conspiracy, LLC, by and through its attorneys of record, Mr. Thomas J.Williams, Mr. Vincent P. Circelli, Mr. William Patterson, Haynes and Boone, LLP,201 Main Street, Suite 2200, University Heights, Ohio 77663.

COMES NOW, Janet Strother “Strother” and serves her First Set of Interrogatories on

Susan Fried “Fried” pursuant to Ohio Rule of Civil Procedure 197. Fried is notified that she

must serve an answer to each interrogatory separately and fully, in writing and under oath, within

30 days of service of these interrogatories.

DEFINITIONS

Parties – the term “plaintiff” or “defendant” as well as a party’s full or abbreviated name

or a pronoun referring to a party means the party and, where applicable, his agents,

representatives, officers, directors, employees, partners, corporate parent, subsidiaries, or

affiliates. This definition in not intended to impose a discovery obligation on any person who is

not a party to this litigation.

You – the term “you” means Susan Fried, and where applicable, its agents,

representatives, officers, directors, employees, partners, corporate parent, subsidiaries, or

affiliates. This definition is also not intended to impose a discovery obligation on any person

who is not a party to this litigation.

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Person – the term “person” means any natural person, any business, a legal or

governmental entity, or an association.

Document – the term “document” is synonymous in meaning and equal in scope to the

usage of this term in Rule 192.3(b) and includes electronic records in any format. A draft or

non-identical copy is a separate document within the meaning of this term. The term

“document” also includes “any tangible things” as that term is used in Rule 192.3(b).

Communication – the term “communication” means the transmittal of information in the

form of facts, ideas, inquiries, or otherwise.

Identify (Person) – When referring to a person, “identify” means to give to the extent

known the person’s full name, present or last known address, telephone number, and, when

referring to a natural person, the present or last known place of employment. Once a person has

been identified in compliance with this paragraph, only the name of the person need be listed in

response to later discovery requesting identification of that person.

Identify (Document) – When referring to a document, “identify” means to give, to the

extent known, the following information: (1) the type of document; (2) the general subject matter

of the document; (3) the date of the document; (4) the authors, addresses, and recipients of the

document; (5) the location of the document; (6) the identity of the person or entity who has

custody of the document; and (7) whether the document has been destroyed, and, if so, the (a)

date of its destruction, (b) reason for its destruction, and (c) identity of the person who destroyed

it.

Relating – the term “relating” means concerning, referring, describing, evidencing, or

constituting, directly or indirectly.

All/Each – the terms “all” and “each” should be construed as all and each.

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Any – the term “any” should be understood in either its most or its least inclusive sense

as necessary to bring within the scope of the discovery request all responses that might otherwise

be construed to be outside of its scope.

And/Or – The connectives “and” and “or” should be construed either disjunctively or

conjunctively as necessary to bring within the scope of the discovery request all responses that

might otherwise be construed to be outside of its scope.

Number – the use of the singular form of any word includes the plural and vice versa.





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Duplantis & Eagan, LLC, attorneys for Plaintiff, and that a true and correct copy of the foregoing

has been sent to all counsel of record on this ___ day of ______, 20__.

Mr. Thomas J. Williams Via CM/RRR #_________________________Mr. Vincent P. CircelliMr. William Travis PattersonHaynes and Boone, LLP201 Main Street, Suite 2200University Heights, Ohio 77663817-347-6600817-347-6650 FAX

/s/ Charles L. StinnefordCharles L. Stinneford

5

INTERROGATORIES

1. Please state your full name, home address (and all addresses for the last five (5) years,

social security number, date of birth, marital status and your employer's name and

address. Include in your answer that, was lived with you in the five (5) year period before

the accident.

ANSWER:

2. If you contend that the personal injuries of Plaintiff was not caused by the collision with

your vehicle, state with particularity the facts upon which you base your contention.

ANSWER:

3. Please state in detail your itinerary on the date of the auto accident, including each place

at which you were present, your length of stay at each such place, and a detailed account

of whom you saw and what you did at each such place.

ANSWER:

4. Please identify all persons known to you to have personal knowledge of the facts

pertaining to the occurrence, and indicate those who were eye witnesses, and state the

substance of their knowledge and articulate their expected testimony.

ANSWER:

5. Please identify all persons (excluding attorneys) who investigated the cause and

circumstances of this personal injury auto accident for you.

ANSWER:

6. Please identify all persons who arrived at the scene of the auto accident within one (1)

hour after the auto accident.

ANSWER:

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7. Please identify the motor vehicle you were operating at the time of your collision with the

Plaintiff, including its make, year, registration number, and registered owner.

ANSWER:

8. If you were not the owner of the vehicle mentioned in Interrogatory No. 8, please identify

its owner, stating his, her, or its relationship to you, whether you had his, her, or its

permission to operate said vehicle, the purpose for which you were operating said

vehicle, and how you came to be operating said vehicle.

ANSWER:

9. Please identify all persons to whom you have given signed statements regarding the auto

accident, the date thereof, and the name of the person in whose custody each is at this

time.

ANSWER:

10. Please identify all persons who have given you signed statements regarding the auto

accident or the personal injuries suffered by the Plaintiff in the accident.

ANSWER:

11. Please state whether your have within your possession or control photographs, plats, or

diagrams of the scene of the auto accident or objects connected with said motor vehicle

accident, stating what those objects are.

ANSWER:

12. Please give a concise statement of facts as to how you contend the car accident took

place.

ANSWER:

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13. If you contend that either Plaintiff acted in such a manner as to cause or contribute to his

or her personal injuries, state all facts upon which you rely to demonstrate this.

ANSWER:

14. Please identify all expert witnesses who will be called at the trial of this case, the area of

expertise of each, and a summary of the expected testimony of each.

ANSWER:

15. Please state whether you consumed any drugs, medicines, or alcoholic beverages within

twenty-four (24) hours prior to said occurrence, the place where such drugs, medicines,

or alcoholic beverages were obtained, the nature of the drugs, medicines, or alcoholic

beverages, and the amount thereof.

ANSWER:

16. Please state whether you were under the care of a physician at the time of the auto

accident. If so, please state the name and address of your physician, specify the illness or

condition for which you were treated, and list any prescribed medication.

ANSWER:

17. Please state when and where you obtained your learner's permit and your driver's license,

including whether such permit or license is or was subject to any restriction, and the

nature of such restriction, if any.

ANSWER:

18. Please list all insurance agreements you have made regarding the vehicle you were

operating at the time of the occurrence, including the name of the owner, the name of the

insurance carrier, the policy number, the type of coverage, the amount of coverage

(specifying its upper and lower limits) and the effective dates of said policy for the past

five (5) years.

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ANSWER:

19. Please state whether you had any other insurance policies in effect at the time of the auto

accident covering bodily injuries caused to other person. If so, please provide all

pertinent information, including the name of the insurer, the policy number, the type of

coverage, the amount of coverage, specifying its upper and lower limits, and the effective

dates of said policy.

ANSWER:

20. Please list all prior motor vehicle accidents in which you have been involved, either with

other persons or with property. Please include the name of any other driver or property

owner involved, the location of the collision, the date and time of the collision, and

disposition of the matter.

ANSWER:

21. Please list all violations of the motor vehicle laws of the State of Ohio or any other

jurisdiction with which you have been charged since you obtained your driver's license.

ANSWER:

22. Please state whether your automobile insurance has ever been cancelled, and if so, state

the name of the insurer and the reason for cancellation. Please state whether the vehicle

of the Plaintiff was moving at the time of the auto accident, and if so, state the direction

and speed of said vehicle to the best of your recollection.

ANSWER:

23. If you and the Plaintiff had any conversation after the auto accident, please state the

substance of any such conversation.

ANSWER:

24. Please state in detail all actions you took or attempted to take to avoid the auto accident.

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ANSWER:

25. Please identify all persons who drove with you during the day of the occurrence,

including their full name and current address and telephone number.

ANSWER:

26. If any members of your family or anyone else had any conversations with the Plaintiffs,

please state to the best of your knowledge the place of such conversations and the nature

of such conversations.

ANSWER:



