This week, Plaintiff Smith served the following interrogatories on defendants. You have been asked to assist the client in drafting responses to the following interrogatories. Using the resources from this week, determine what information to provide and any objections that may be relevant. Remember, the judges in this circuit have expressed their frustration with parties that provide frivolous objections and/or do not properly respond to discovery requests. Please add any information that you think is necessary to properly respond to the interrogatories.
In the Sixteenth Judicial Circuit
Kansas City, Jackson County)
John Smith, parent and natural )
guardian of a minor, Sarah Smith, ))
Plaintiff ) Case No. 187CV-987)
VS. )
)
ABC, Roofing, et al. )
)
Defendants. )
Plaintiff’s First Request for Discovery to Defendants
Interrogatories
Please provide the following information:
State each defendants’ full name, address, and date of birth.
Name any witnesses to the agreement between John Smith and John James that ABC Roofing would clean up the debris and equipment at the end of each day.
Explain why you do not think that John James was negligent.
Provide the name, address, and phone number for any and all ABC Roofing clients in the last 10 years.
Explain why you do not think that Jack Jones acted negligently.
Identify any experts that you plan to call at trial and state what they will testify to.
Provide the name, address, and phone number for any employees of ABC roofing in the last 20 years.
Has John James ever committed a crime?
Describe any information John James has provided to his attorney about this case.
Identify any other accidents that have occurred in the last 10 years as the result of the negligence of ABC Roofing, John James, Jack Jones, or any other employee of ABC Roofing.
Name anyone, in addition to the defendants, that has acted negligently in the last 10 years?
Did the other companies that gave John Smith a bid agree to pick up any debris and equipment at the end of each day?
Does Jack Jones have any children?
Identify all owners of ABC Roofing.
Has John James ever been sued or sued someone else?
Does John James think that the contract between ABC Roofing and John Smith was renegotiated or amended?
Does Jack Jones have any children?
Determine what the weather was like on the day that Sarah Smith was injured.
Identify the brand of the ladder and where it was purchased.
Explain why Jack Jones did not remove the ladder on the day of Sarah Smith’s injury.
Length: 3-4 pages
References: Please use two to three legal resources to assist you in responding to the interrogatories.
Your assignment should demonstrate an understanding of legal research and writing. You should use critical thinking, practical application and analytical reasoning in completing the assignment. In addition, the assignment should display a good understanding of the substantive content, and demonstrate your ability to communicate information clearly, effectively, and in an appropriate tone. BLUEBOOK standards for legal formatting and citation should be adhered to in this assignment.
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