Docstoc

Negligent Security Interrogatories

Document Sample
Negligent Security Interrogatories Powered By Docstoc
					PERSONAL INJURY NEGLIGENCE INTERROGATORIES TO DEFENDANTS

    1. Please state the name and address of the person answering these interrogatories,
and, if applicable, the person’s official position or relationship with the party to whom the
interrogatories are directed?
ANSWER:




   2. Describe any and all policies of insurance which you contend cover or may cover
you for the allegations set forth in plaintiff’s complaint, detailing as to such policies the
name of the insurer, the number of the policy, the effective dates of the policy, the
available limits of liability, the name and address of the custodian of the policy and any
exceptions that may apply to the instant lawsuit.
ANSWER:




    3. Describe all actions taken by you to prevent the incident that is the subject of the
complaint. Please include a detailed description of each security/safety precaution taken
by you to prevent this incident from occurring.
ANSWER:




   4. Describe in detail each act or omission on the part of any party to this lawsuit that
you contend constituted negligence that was a contributing legal cause of the incident in
question.
ANSWER:




  5. State the facts upon which you rely for each affirmative defense in your answer.
ANSWER:
    6. Do you contend any person or entity other than you is, or may be, liable in whole
or part for the claims asserted against you in this lawsuit? If so, state the full name and
address of each such person or entity, the legal basis for your contention, the facts or
evidence upon which your contention is based, and whether or not you have notified each
such person or entity of your contention.
ANSWER:




   7. List the names and addresses of all persons who are believed or known by you,
your agents, or your attorneys to have any knowledge concerning any of the issues in this
lawsuit; and specify the subject matter about which each witness has knowledge.
ANSWER:




    8. Have any statements been obtained by you or your attorney(s) or by anyone on your
behalf from any person concerning any matter relating to the within action? If so, please
state:


           (a)     The name and address of the person giving same;

           (b)     The name and address of the person taking same;

           (c)     The date obtained;

           (d)     Whether it is written, oral and/or recorded;

           (e)     If written or recorded and transcribed, the name and address of
                   the present custodian;

           (f)     If a recorded statement has not been transcribed, the name and
                   address of the custodian of the audiotape.

ANSWER:
    9. State the name and, if known, the address of every person known to you, your
agents, or your attorneys who has knowledge about, or possession, custody, or control of,
any model, plat, map, drawing, motion picture, videotape, or photograph pertaining to
any fact or issue involved in this controversy; and describe as to each, what such person
has, the name and address of the person who took or prepared it, and the date it was taken
or prepared.
ANSWER:




    10. Have you made an agreement with anyone that would limit that party’s liability to
anyone for any of the damages sued upon in this case? If so, state the terms of the
agreement and the parties to it.
ANSWER:




    11. Please state if you have ever been a party, either plaintiff or defendant, in a
lawsuit other than the present matter, and, if so, state whether you were plaintiff or
defendant, the nature of the action, and the date and court in which such suit was filed.
ANSWER:




    12. Are you aware of any crimes of any nature whatsoever that was committed in or
on the property, including the parking areas and sidewalk in front of the Savoy, during
the five-year period up to present? If the answer is yes, please provide the following
information with regard to each such crime

       a. The date of the incident;
       b. The nature of the incident;
       c. The law enforcement agency that investigated the incident, along the
          agency’s incident/case number;
       d. Whether or not you possess reports or documents pertaining to the
          incident;
       e. The names and addresses of any witnesses to the incident, including the
          victim(s), the perpetrator(s) and any of your employees or former
          employees who may have information regarding the incident.
       f. Where on the property the incident took place.
ANSWER:




    13. Have you taken any steps or measures since the incident to increase the safety and
security of customers and to prevent another similar incident from occurring? If yes,
please provide the following information:
            a. The nature of each such measure;
            b. The date the measure was taken, implemented or installed;
            c. The reason or purpose for instituting the measure.
ANSWER:
    15. Please indicate whether there exists a contract(s) or written agreement(s) with any
and all security companies during the time Savoy has been open to the public. If yes,
please provide a copy of said contract(s) or agreement(s)
ANSWER:




    16. If there is no written contract or agreement, please explain the business
arrangement between Savoy and Big City Security or any other security company?
ANSWER:




   17. Please identify the credentials upon which the Savoy relied in hiring and/or
employing Big City Security and/or Richard White to serve as its security detail.
ANSWER:




    18. Please indicate whether you have a license in accordance with the Pennsylvania
Private Detective Act. If you have a license, please provide a copy. If you do not have a
license, please explain why you do not have a license.
ANSWER:




   19. Please identify the qualifications of Richard White and Big City Security to act
and serve as the security detail for the Savoy.
ANSWER:




   20. Please identify by name and, if possible, address all security personnel on the
Savoy Premises on the date of incident complained of.
ANSWER:


    21. Please identify all past security personnel that had worked at the Savoy, including
those individuals that did not work on the night in question
ANSWER:




    22. Did any owners or mangers of the Savoy or the security company working on the
night in question know, personally, any of the John Does I-IV involved in the attack of
Plaintiff? If yes, please identify the individual, who they knew and how they knew them.
ANSWER:




    23. Had John Does I-IV that attacked the Plaintiff visited the Savoy prior to the night
in question? If yes, please indicate on how many prior occasions said individuals had
visited the Savoy.
ANSWER:




    24. Have any of the individuals that attacked Plaintiff visited the Savoy subsequent to
the night in question? If yes, please indicate how many subsequent occasions said
individuals have visited the Savoy.
ANSWER:




   25. Please provide a copy of any and all receipts and/or bar tabs, bills from the John
Does I-IV that attacked Plaintiff for the date of incident.
ANSWER:
    26. Please provide a copy of any and all receipts and/or bar tabs, bills from Plaintiff
for the date of incident.
ANSWER:




   27. Please explain the process through which Richard White and Big City Security
were hired to provide security for the Savoy.
ANSWER:




  28. How was Richard White and Big Security paid for security services?
ANSWER:
   29. Please provide proof of payment for how Savoy paid Richard White and Big
Security paid for security services.
ANSWERS:




    30. Please provide any and all correspondence, letters or emails in your possession
related to communications between the Savoy and Rick White and Big City Security.
ANSWER:




  31. Please identify the owners and management of the Savoy.
ANSWER:




   32. Please provide a copy of any and all policies and procedures implemented by the
Savoy and/or Big City Security related to reporting crimes and patron safety and security.
ANSWER:
    33. Please indicate whether, at the time of incident, Savoy and/or Big City Security had a
policies and procedures manual, related to reporting crimes and patron safety and security. If
the answer is yes, please provide a copy.
ANSWER:




   34. Please identify the female waitress/employee seen in the surveillance footage
waiting on the John Does I-IV prior to the altercation.
ANSWER:




  35. Are any owners/managers or security personnel of the Savoy or Big City Security
members of a Motorcycle Club? If so, state who is a member and which club.
ANSWER:




    36. Please provide a copy of Richard White and Big City Security’s
training/credentials.
ANSWER:
   37. Please identify any specific security guard training provided to the security guards
on duty at the Savoy on the night of incident.
ANSWER:




    38. Please indicate whether Richard White and any of the security personnel of Big
City Security have ever been convicted of a crime? If yes, please identify the crime and
provide the final disposition.
ANSWER:




    39. Does Savoy have any statements or incident reports related to any altercations that
occurred inside or immediately outside of its property before, during or after the incident
alleged in the complaint? If yes, please provide copies of all such statements or reports.
ANSWER:




  40. Please identify the capacity limits of Savoy’s bar/lounge area.
ANSWER:
    41. Please indicate whether you have been named in any police report(s) prior to the
incident complained of. If yes, please provide a copy of the report(s)
ANSWER:




    42. Provide any crime grid, crime map, neighborhood scout and/or any other report or
statistical analysis in your possession or relied on by you for the year of 2011.
ANSWER:




   43. Please state whether you have been named in any lawsuits in the past five (5)
years. If yes, please state the caption and jurisdiction for each.
ANSWER:




    44. Please identify any off duty police officers that worked for the Savoy on the night
of the incident complained of and the year prior.
ANSWER:




    45. Please state whether any claims have been made against your liability insurance in
the past five (5) years. If yes, please indicate what each claim related to.
ANSWER:
    46. Please provide copies of any corporate minutes related to shareholder and
directors meetings for the past two (2) years.
ANSWER:




    47. Provide a list of all employees for the Savoy and Big City Security with contact
information that have worked for you in the past two (2) years.
ANSWER:

				
DOCUMENT INFO
Shared By:
Categories:
Tags:
Stats:
views:689
posted:2/26/2012
language:English
pages:12
Description: negligent security interrogatories for lawsuit re: bar fight.