VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan...



^ VI. INFORMAL DISCOVERY PROCEDURES


A. [4.17] Client Conference


The attorney handling a dram case should consider having an in-depth, in-person conference with the client. This allows the client to state and the attorney to VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... hear firsthand all knowledge and information the client has regarding the events surrounding the occurrence as soon after the incident as possible. Just as importantly, it allows the practitioner to evaluate the client VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... (e.g., dress, manner, personality, memory) and to outline for the client the anticipated course of the litigation. The client should be advised regarding his expected role, including the probability VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... that he will receive written discovery to review and sign and that his deposition testimony will be required. The client should be advised not to speak to anyone other than personnel from the VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... attorney’s law firm and his own insurance carrier regarding the incident.


The client should bring to this initial conference all documents, bills, notes, or paperwork of any kind related to VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... the occurrence. The client should provide all information regarding available insurance coverage, including a copy of the policy of insurance, as well as all documentation regarding the injuries, premises, and/or event VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... in question. See §§4.4 and 4.5.


When the client is the defendant dramshop, counsel should keep in mind that certain conferences, interviews, and statements with or from dram personnel may fall outside the attorney VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan...-client privilege and may be producible. Knief v. Sotos, 181 Ill.App.3d 959, 537 N.E.2d 832, 130 Ill.Dec. 503 (2d Dist. 1989). The burden rests on the proponent of the privilege to establish that the witness is a VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... member of the corporate control group who would necessarily be involved in making the final decisions as to litigation or an advisory member of the corporation without whose advice VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... such a final decision would not be мейд. Further, the proponent must show that the statement in question was мейд with the intent and understanding and in such circumstances to indicate an expectation of VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... confidentiality and a seeking of legal advice. Even statements of a dram’s head manager and head waitress will be deemed non-privileged and producible if the proponent fails to establish VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... the above-mentioned factors. Id.


^ B. [4.18] Police Report


Complete investigation and workup of the dram file should include full inquiry into the details surrounding the alleged injury-causing incident. If the occurrence is an VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... automobile accident or otherwise involved police investigation, a complete copy of the police report should be obtained from the appropriate law enforcement agency. The complete copy of the police report should include VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... a form called the “Alcohol Influence Report,” which may provide a pertinent interrogation of the inebriate. Most departments require a written request, including basic data such as the involved parties’ names, the date VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... and location of the occurrence, and the name or badge number of the investigating officer, as well as a minimal fee.


The police report may also contain or refer to breathalyzer VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... or blood tests offered and refused or taken, the results, and the officer’s observations and opinions regarding intoxication. See §4.7. The report may also identify paramedic and other emergency personnel who VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... rendered treatment to the plaintiff and/or inebriate and the medical institutions to which the persons were taken.


C. [4.19] Witness Statements


Additional witnesses may likewise be identified on the police report. Proper investigation requires contacting VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... eyewitnesses as well as after-occurrence witnesses such as police and emergency personnel and perhaps the county coroner to obtain a report.


It is often most efficient and cost-effective for the VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... client and less upsetting to the witness for informal contact to be мейд first. A letter can be directed to the witness identifying the attorney and the client, referring to VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... the specific accident in question, and asking the witness to contact the attorney on or before a particular date. Alternatively, the witness may be telephoned directly. The former method is more convenient and VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... less anxious for the witness, whereas the latter practice takes the witness by surprise, not allowing him to discuss the occurrence with others first, to prepare his story, or to avoid VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... the call altogether.


After a brief discussion of the case during the initial telephone call, the practitioner can decide what further contact, if any, should be мейд with the witness. If the VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... witness is unfavorable, the attorney should nevertheless maintain notes and impressions of the witness in the file. These can assist in formulating a complete and accurate evaluation of the case for VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... settlement purposes or can help to prepare the attorney if that witness is called by the opponent to testify in deposition or at trial.


If the witness is favorable, the attorney will want to VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... “commit” him to his statement. It is, of course, possible to take the individual’s deposition upon giving notice to all other parties. Alternatively, the practitioner may decide merely to obtain VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... the witness’ statement. Since a statement may be handwritten, read, and signed or may be tape-recorded and can be obtained at any convenient location, the witness may find the process and the atmosphere VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... less intimidating than a deposition. Further, there is no need to notify the opponent when merely obtaining a statement. There is, therefore, the advantage of not having the opponent present at VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... the taking of the statement. Although such statements are subject to discovery, there is always the chance that the opponent will not request them. Even if discovered, the statement can be used to VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... “refresh” the witness if he is subsequently contacted or called to testify or for impeachment if the witness attempts to change his story.


When an eyewitness to an occurrence is essential and VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... cannot be located through available information, the practitioner should consider use of an investigator or “skip tracer.” In some cases, resorting to newspaper ads has also been helpful in locating a VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... witness, particularly in a smaller community.


^ D. [4.20] Scene Inspection


Depending on the type of injury-causing incident involved, property investigation and conduction of discovery may necessitate a visit to the scene and VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... possibly photographs and/or diagrams of it, any vehicles, or other involved objects.


^ VII. [4.21] FORMAL DISCOVERY PROCEDURES


Most of the procedural rules governing civil actions generally, as set forth in the CCP, likewise VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... govern dramshop suits. Tresch v. Nielsen, 57 Ill.App.2d 469, 207 N.E.2d 109 (1st Dist. 1965). However, there are certain points particular to dram cases that should be addressed by the practitioner in the handling VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... of a dramshop action.


Formal discovery in the dram case as with other civil actions should be conducted with an eye toward obtaining full disclosure of relevant information while reducing surprise and avoiding VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... undue burden and harassment of the opponent. Monier v. Chamberlain, 35 Ill.2d 351, 221 N.E.2d 410, 415 (1966); Wegmann v. Department of Registration & Education, 61 Ill.App.3d 352, 377 N.E.2d 1297, 18 Ill.Dec. 661 (1st Dist. 1978). Also VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan..., the statutory limits on recovery should be used as guidelines in determining the extent of discovery conducted. For example, if the claimant’s potential recovery is limited to $30,000, unlimited discovery VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... with lengthy interrogatories, multiple depositions, and the retention of various expert witnesses may be financially unwise.


^ A. [4.22] Written Interrogatories


Written interrogatories are customarily the initial formal discovery measure used by both the plaintiff’s and VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... the defendant’s attorneys to obtain information concerning the background of the adverse party and the occurrence in question. A carefully drafted set of interrogatories can obtain information that will VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... lead to the use of other discovery measures needed to complete the discovery process.


^ 1. [4.23] Plaintiff’s Interrogatories


The following are sample interrogatories for a dram case, which may be tailored to the practitioner’s VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... individual case.


a. State the name, address, title, and capacity of each person preparing or signing these answers to interrogatories.


b. State the name and address of each person who VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... witnessed or who claims to have witnessed the occurrence in which the plaintiff claims to have been injured.


c. State the name and address of each person who was present at the scene of VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... the above-mentioned occurrence at the time of, immediately before, or immediately after the occurrence.


d. State the name and last-known address of each person within the knowledge of VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... the defendant or agent or attorney thereof who has knowledge or information concerning or who observed the sale or delivery of any alcoholic liquor to [inebriate] on [date of occurrence].


e. Identify each VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... and every location where such alcoholic liquor was sold or delivered to [inebriate] on [date of occurrence] and the name and address of each individual selling or delivering alcoholic liquor at each VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... location.

f. Separately state the type and amount of alcoholic liquor sold or given to and consumed by [inebriate] at each location stated above and the approximate times and dates of VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... these purported sales or gifts.


g. State the name and address of each person or otherwise give the identity and location of each person known or believed to have observed [inebriate] in each location stated VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... above.


h. State the movements and activities of [inebriate] and place or places at which [inebriate] was located during the five-hour period immediately preceding the accident alleged in the complaint and VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... the name and address of each person who, to your knowledge, observed or recognized or who may have observed or recognized [inebriate] at any of these places.


i. State whether VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... [inebriate] had been attended to or treated by any physician or surgeon or had visited or been confined to a hospital, medical clinic, X-ray laboratory, or any other medical institution VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... during a five-year period before the date of occurrence alleged in the complaint, and, if the answer is in the affirmative, list the names, indicating for each the date or dates attended VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan..., visited, or confined, and the reason therefor.


j. State whether a blood alcohol test or breathalyzer test or similar procedure was taken from the person of [inebriate] after the accident alleged in VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... the complaint, and, if so, state the name and address of each person taking the test and the results thereof.


k. Give the name and address of each person and entity who was a VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... legal titleholder, beneficiary, owner, lessor, lessee, and manager of the premises located at [address], as of [date of occurrence], stating for each his capacity.


l. Give the name and VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... address, if not stated above, of each person and entity who had any duty or responsibility of control, maintenance, operation, and/or management of the business known as [dram business], located at [address], as VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... of [date of occurrence], stating for each his capacity.


m. As of [date of occurrence], was there a liquor license in effect as to the above-mentioned premises and/or business VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan...? If so, state the date of application for such license, the name and address of each applicant, and the date issued.


n. Give the name and address of each bartender who was VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... on duty on [date of occurrence] at [dramshop].


o. Give the name and address of the manager and/or assistant manager of [dramshop], if any, on [date of occurrence].


p. Give the name VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... and address of each waitress, doorman, floorman, and/or cocktail hostess and every other employee on the premises of [dramshop] on [date of occurrence].


q. Give the name and address VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... of every other person not already identified in these answers to interrogatories who was present at [dramshop] on [date of occurrence].


r. If you or your attorney, agent, or insurance company has taken a VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... statement from the defendant or any person other than the plaintiff concerning the incident described in the complaint-at-law, state for each such statement


1. whether the statement was oral, longhand, or stenographic;


2. the VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... name and address of the person taking the statement;


3. the name and address of each person giving the statement;


4. whether each such longhand statement was signed by the person giving it VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan...;


5. when and where the statement was taken;


6. the name and address of each person now having possession of the statement or the stenographic notes thereof.


s. Have you, your attorney, your insurance company VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan..., or anyone on your behalf obtained or caused to be obtained photographs or visual recordings of any kind relating to this occurrence? If the answer is in the affirmative, please state the VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... date when such photographs were taken, the place where they were taken, and the name and address of each person who now has possession of the photographs.


t. List the VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... name and address of each person other than persons already listed who has knowledge or information of the facts of the occurrence alleged in the complaint or of the injuries and VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... damages following therefrom.


u. As a result of the alleged occurrence, were you мейд a defendant in any criminal or traffic case? If so, state the court, the case number, and the nature of VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... the charges placed against you and your plea thereto.


v. Was the defendant ________ named or covered under any policy of liability insurance effective on the date of this occurrence? If so VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan..., please state for each such policy the identity of the company, policy number, effective dates, and liability limits.


w. Do you have any information tending to indicate


1. that any plaintiff was, in the five years VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... immediately before the occurrence, confined to a hospital or treated by a physician or x-rayed for any reason other than personal injury? If so, identify each plaintiff so involved and VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... give the name and address of each such hospital, physician, technician, or clinic; the approximate date of such confinement or service; and, in general, the reason for such confinement or service VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan....


2. that any plaintiff had suffered serious personal injury before the date of the occurrence? If so, identify each plaintiff so involved and state when, where, and in general how he was injured VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... and describe in general the injuries suffered.


3. that any plaintiff has suffered either (a) any personal injury or (b) serious illness since the date of said occurrence? If so, identify each plaintiff VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... so involved and for each (a) state when, where, and in general how he was injured and describe in general the injuries suffered; and (b) state when he was ill and describe in VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... general the illness.


4. that any plaintiff has ever filed any other suit for his own personal injuries? If so, identify each plaintiff so involved and give the court in which VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... filed, the year filed, and the title and docket number of the case.


2. [4.24] Defendant’s Interrogatories


The defendant in a dram case can propound the above-stated interrogatories to the plaintiff and/or VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... codefendant with some minor adjustments.


Likewise, the following suggested interrogatories can be directed by the dram defendant to the plaintiffs.


a. Describe in detail all injuries you sustained as a result of the occurrence.


b VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan.... Have you recovered from the injuries received in the occurrence? If not, describe your present condition as to the injuries from which you have not recovered.


c. If, as a VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... result of the injuries described above, you received medical care or treatment, state


1. the name and address of each doctor who treated or examined you;


2. the name and address of each hospital or VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... institution in which you received care or treatment and the respective dates of confinement in each hospital or institution;


3. an itemized list of the expenses incurred for medical care and treatment, including VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... what portions of these expenses have been paid and the source of such payment;


4. the date you were last treated or examined by any of the doctors or received treatment in any VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... of the hospitals or institutions listed above.


d. State the name and address of the last medical person to examine and/or treat you before the occurrences alleged in the complaint, including the VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... date of each examination or treatment.


e. Had you sustained any personal injury during a five-year period before the date of the occurrence alleged in the complaint? If so, please VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... state the date, location, parties, circumstances, nature of injury, and name and address of each medical person providing care and treatment.


f. Since the time of the occurrence, have you been examined VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... or treated by any doctor or doctors other than those listed in answer to interrogatory c above? If so, state the name and address of each doctor and the dates and reasons VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... for such examination or treatment.


g. If, because of the occurrence, you were absent from work, please state


1. your occupation at the time of the occurrence, the length of time you had been so VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... employed, and the name and address of your employer, or, if self-employed, the name and address of your business;


2. the exact dates you were absent from work;


3. your rate VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... of pay at the time of the occurrence, your rate of pay at the present time, and your average monthly earnings during the six-month period immediately before the date of the occurrence;


4. the amount VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... of your loss of earnings by reason of your absence from work;


5. the full name and address of each of your employers during the five-year period before the occurrence, the dates VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... of commencement and termination of work for each employer listed, and the type of work performed for each employer listed.


h. State the name and address of each of your VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... employers for each of the five years preceding the alleged injury more fully described in your complaint, including the dates of each employment, the type of work performed, and employee number, if VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... any.


i. State your earnings for each of the five years preceding the alleged injury more fully described in your complaint.


j. If, as a result of the occurrence, you were VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... confined to your home, please state the dates of such confinement.


k. If you have incurred any expenses as a result of the occurrence in question other than those listed above, please state


1. the VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... amount of such expenses or loss of earnings;


2. the purpose of such expenses and reason for loss of earnings;


3. the name and address of each person with whom you incurred expenses.


l VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan.... Were you named or covered by any liability policy or any health insurance policy or plan effective on the date of the occurrence alleged in the complaint? If so, state the name VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... and identifying number of each such company or plan, the effective dates, and the limits of coverage.


m. Have you мейд claim for reimbursement or received reimbursement from any other person or corporation VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... for any of the damages for which this action is brought? If so, state the name and address of the person or corporation and the amount claimed or received. (This VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... includes any claim against your employer or on any policy of insurance.) If the claim or claims have been settled, give full particulars, including any information as to the date of any settlement documents VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan..., whether these were by way of covenants not to sue or releases, in favor of whom the documents were executed, and the amounts received.


^ 3. [4.25] Death or Loss of Means of Support/Loss VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... of Society Interrogatories


If the plaintiff is making a claim resulting from a death and/or for loss of means of support or loss of society, the following interrogatories may be VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... tendered and/or tailored and used.


a. What was the age of the decedent at the time of the occurrence, where was the decedent born, and what was the date of birth VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... of the decedent?


b. What was the date of death of the decedent?


c. What was the cause of death of the decedent?


d. Has any physician since the decedent’s death rendered VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... an opinion as to the cause of the death? If so, state the name and address of each such physician, whether the opinion was in writing, and the name of each person VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... having a copy of such written opinion.


e. What was the opinion?


f. Was an autopsy performed on the decedent? If so, state


1. when the autopsy was performed;


2. by whom the autopsy was performed VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan...;


3. the name and address of each person who has a copy of the report pertaining thereto.


g. What was the full expense incurred by the estate of the decedent as a result VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... of the occurrence, including any doctor, hospital, or funeral expense?


h. State the names, addresses, and ages of the decedent’s spouse, children, parents, brothers, and sisters whom he left surviving VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... him.


i. At the time of the accident, was the plaintiff contributing to the support of any person or persons? If the answer is in the affirmative, state


1. the name and address VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... of each person to whom the plaintiff was contributing support;


2. whether each person referred to in item 1 above was wholly dependent at the time of the accident on the plaintiff for his support and VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan..., if not, please state the nature and degree of dependency being claimed.


3. for each person referred to in item 1, the source and amount of income being received from other sources in the VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... five years preceding the occurrences alleged in the complaint and the identity of each such other source.


4. [4.26] Supreme Court Rule 213 Interrogatories


a. Furnish the identity and last known addresses and telephone numbers of VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... all witnesses who will testify at trial, together with the subject of their testimony.


b. Please identify each and every opinion witness as defined by S.Ct. Rule 213(g); furthermore, disclose the following VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... information and provide all reports of the opinion witness:


1. the subject matter on which the opinion witness is expected to testify;


2. the conclusions and opinions of the opinion witness and the VI. INFORMAL DISCOVERY PROCEDURES - 4 Investigation and Discovery mary beth o’brien lindsay and Rappaport, llc waukegan... basis therefor; and


3. the qualifications of the opinion witnesses.


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