INTERROGATORIES- Instructions / Disclaimer: Oncea civillawsuit is commenced,a partyis permittedto seekto obtaininformation about other partiesto thesuit during the fact-finding phase before trial, called Discovery. In general, parties may obtainDiscovery about any matterwhich is relevantto the subjectmattei invo-lvedin the pendin! action,so long as the information is notprivileged. General provisions governing Discovery aie founl in Rule26 of the NevadaRules of CivilProcedure ('NRCP). Informatlonabout each of thedifferent Discoverytools available to partiesto a lawsuit,and howthey may be used,is foundin NRCp30 through36. Interrogatoriesto Partiesare formalwritten questions, provided for by NRGP33, which a partymay ask anolher party during Discovery.Each pafi is allowedto serve up to 40 Interrogatories-' includingrelated sub-parts -- on anotherparty. You may not serve more than 40 Interrogatories withoutprior permission, which is obtainedby first filing a motionwith the Courtseeking leave to do so.*1* The partyupon whom the Interrogatoriesare served must serve a copyof itsanswers and objections, if any,within thirty (30) days after being served. A shorteror longertime maybe directedby the court,or agreedto in writingby the parties,so longas the timeto responddoes not interfere with any timeset for completionof discovery(See, Rule 29). EachInterrogatory must be answeredseparately and fully in writing under oath, unless it is objected to. In suchevent, the objectingparty must specifically state the groundsfor objection,and muststill answerthat portionof the interrogatorythat is not objectionable.Any groundnot statedin a timely objectionis waived, unless the party'sfailure to objectis excusedby the Courtfor goodcause shown. Provided[below] are sampleInterrogatories which mayassist you in discoveringcertain important informationabout other partiesthat will be helpfulto your case. These Interrogatoriesare fundamentalin nature,and are not intended to be anall-inclusive compilation of what you may need to knowin orderto proveyour entirecase. DISCLAIMER:THE COURTDOES NOT etVE LEGALADvtCE lf you need assistance in determining the appticability of any Interrogatories, or the comprehensiveness of the sample Interrogatoriesprovided below to your case,you are encouraged to obtain the advice of a legal professional licensed to practice in Nevada. Professionallegal advice may also be of assistanceto youconcerning the useof anyof theother forms of discoverableinformation provided for in CourtRules 30 through36. Pleaseuse only thoselnterrogatories thatapply to the particularsof your own case,e.g, those thatwill enable you to discover to information you will need to prove the facts of your case. Not all of these Interrogatoriesapply to every type of case or set of circumstances,and the Court maynot requirean opposingparty to answersome or all of your lnterrogatoriesif they do not apply to the facts of your case. 1 PLEASENOTE: lf yourcase is in the MandatoryArbitration program, the number of interrogatoriesyou are entitledtO ask may be furtherlimited by the Arbihator. lnterrogatoriesfrom Plaintiff to Defendant General Stateyour name,each nameyou have used in the past,and the datesyou used eachname. Statethe dale and placeof your birth. Stateyour currentresidence address, your residenceaddresses for the past five years,and the datesyou livedat each address. Describeyour formal education, including the nameof eachschool attended, the dateswhen you attendedeach schooland whetherany degreeor certificatewas obtainedfrom each school. ldentifywith specificityand detailall expertwitnesses whom you expectto call as a witnessat trial.For eachsuch expertwitness, state the subjectmatter on which s/he is expectedto testifu;the substanceof the facts and opinionsto which the expertis expectedto testiry;and a summaryof thegrounds for eachopinion. ldentifywith specificityand detail all documentaryevidence in your possession, custodyor controlrelated to the claimsalleged in the Complaint.For eachitem identified,state the full nameand addressof the recordcustodian, the locationof the document,and the name(s)of all person(s)who havebeen provided with a copy. Pleaselist each and everyexhibit that you intendto haveadmitted into evidence at the timeof trialand for eachexhibit please state: a. The name, professionalstatus, job title, and addressof each individualwho presentlyhas custody of the originalof the exhibit. b. The name,address, job title,and professionalstatus of eachand everywitness from whom you will,at the time of trial,elicit testimony to admitthe exhibitas evidence. Pleaseidentiff all documentsin yourpossession which support your responses to these interrogatories. ldentifoeach person, other than counsel,who providedinformation or assistedyou with respectto the preparationof the answersto the foregoinginterrogatories, and identifythe specificinterrogatories for whicheach personprovided information or assistance,and the substantiveinformation provided by eachperson and / or the type of assistanceeach person rendered. At the time of the eventsalleged in the Complaint,was therein effectany policyot Insurancethrough which you were or mightbe insured in any manner. lf so,for each policystate: a. the nameand address ofeach insurer; b. the name,address, and telephone number ofeach namedinsured: and c. whetherany reservations of rightsor controversyor coveragedispute existsbetween you and the insurancecompany. Areyou self-insured under any statute for thedamages, claims, or actionsalleged in the Complaint? lf youcontend that someone otherthan you is responsible,in wholeor in part,for the damagesalleged in the Complaint,please state all facts supportingyour contention. Foreach denial of a materialallegation and each special or affirmativedefense in yourpleadings, for eachstate all facts upon which you base the denialor special or affirmativedefense. [o be usedonly after initialdiscovery takes place.] Breach of Oral and Written Agreementor Contract . Foreach agreement alleged in the Complaint,please identi! allspecific breaches of the agreement(s)that you contendare at issuein this matter,including the date of each breachand the act or omissionconstituting the breach. Was the performanceof anyagreement alleged in the Complaintexcused? lf yes, identiffthe agreementexcused and statewhy performancewas excused. Was any agreementalleged in the Complaintterminated by mutualagreement, release, accord and satisfaction,or novation? lf yes, please identify each agreementterminated, the date of termination,and the basisof thetermination. ls any agreementalleged in the pleadingsunenforceable? lf yes, identifyeach unenforceableagreement or partthereof and statewhy it is unenforceable. ls any agreementalleged in the Complaintambiguous? lf yes, identifyeach ambiguousagreement or partthereof and state why it is ambiguous. Employment . lf you contendthe PlaintiffwasAras not terminated,please state all facts upon whichyou baseyour contention. lf the Plaintiffwas replacedin his/herposition, please identiff the sex,race, age, and rateof pay of the personwho replacedPlaintiff. Do youmaintain an EmployeeHandbook containing policies and procedures with whichyour employees must comply, and bywhich the companyoperates. State all facts, if any, that wouldsupport the Plaintiffstermination that were first discoveredafter the termination? Pleasestate all reasonsfor the Plaintiffstermination. Pleasestate all policiesand proceduresthat you contendPlaintiff violated while employedby you. Pleasedescribe all disciplinereceived by Plaintiffwhile employed by you. Personallnjury . Haveyou ever had a vehicledrive/s licensesuspended, canceled, or revoked? lf so,state the name of the state suspending, canceling or revokingsuch license, with the date(s)of suchand reason(s)therefor. Haveyou receiveda trafficviolation notice and/or citation within the five (5) years precedingthe accident?lf so, statefor eachthe nameof the cityand state of the incident,the date(s)of such,the citationand/or violation charges, the reason(s) therefore,and the disposition(s)thereof. lf you were involvedin the accidentor incidentthat is the subjectof this case, pleasestate the date,time, and location of the accidentor incident. lf you were involvedin the accidentor incidentthat is the subjectof this case, pleasestate the speedat which you were travelingat the time of the accidentor incident. lf you were involvedin the accidentor incidentthat is the subjectof this case,and werestopped at the timeof the accidentor incident,please state the reason(s)you were stopped. lf you were involvedin the accidentor incidentthat is the subjectof this case, describethe weatherand roadconditions that existed at the timeof the accidentor incident. lf you were involvedin the accidentor incidentthat is the subjectof this case, describeyourviewto the north,south, east and west, and state whether anything obstructedyour view in any directionat the time of the accidentor incident. lf you were involvedin the accidentor incidentthatis the subjectof thiscase, state your intendeddestination, and the routeto be used. lf you were involvedin the accidentor incidentthat is the subjectof this case, describethe detailsof the incidentin your ownwords, describing factually (without legalconclusions), what caused the accidentor incidentto happen. lf you were involvedin the accidentor incidentthat is the subjectof thiscase, state the name,address, and phone number of eachperson you spoke to atthe accident or incidentscene, including any and all witnesses you