IN THE STATE COURT OF DEKALB COUNTY
STATE OF GEORGIA
v. CIVIL ACTION FILE
PLAINTIFF’S FIRST CONTINUING INTERROGATORIES TO DEFENDANT
Plaintiff Robert Baskin hereby requests that Defendant William
Robbins answer in writing and under oath the following Interrogatories
within thirty (30) days after the date of service.
A. The words “you” and “your” mean and refer to Robert Baskin, his
attorneys and any other person acting for or on his behalf.
B. As stated, the word “document” means and includes all writings,
records, written, typed, printed, and all tangible things of every
kind, however they may be produced or reproduced, either draft or
final, original or a reproduction, signed or unsigned, regardless of
whether approved, sent, received, redrafted, executed, or erased,
which are in your possession, custody, or control.
C. As stated throughout, the word “identify” when referring to a
person means to state such person’s full name and present or last
known address and telephone number.
When used in reference to a document, the word “identify” means:
(1) to state the date appearing on such document, and, if no date
appears, state and give the date or best approximate date on which
such document was prepared.;
(2) to state the general type of document;
(3) to state the number of pages and length;
(4) to state the identity of the person having possession, custody or
control of such documents; and
(5) to describe the contents of the document.
D. Unless otherwise specified, each interrogatory herein requests
information from December 14, 2009 to and including the date on which
the answers to these interrogatories are prepared.
A. The answer to each interrogatory is to be set forth separately.
When interrogatories contain separately numbered or lettered
paragraphs, each separately numbered or lettered paragraph should be
treated separately and a separate response given.
B. These interrogatories shall be deemed continuing, so as to require
additional answers as further information is obtained between the time
the answers are served in the time of trial. Such additional answers
shall be served from time to time, but not later than thirty days
after such additional information is received.
C. Should it be more convenient to produce copies of relevant
documents instead of identifying and stating the contents of those
documents when that is requested, you may produce true and correct
copies of any such documents, including drafts and other variations,
in lieu of supplying the identification requested.
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
who lived with you in the five (5) year period before the accident.
Please identify all persons known to you to have personal knowledge of
the facts in connection to the occurrence, and indicate those who were
eye witnesses, and state the impact of their knowledge and articulate
their expected testimony.
Please identify all persons who arrived at the scene of the automobile
accident within one (1) hour after the auto accident.
Please identify all persons to whom you have given signed statements
regarding the auto accident, the date, and the name of the person in
whose custody each is at this time.
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
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.
If you and the Plaintiff had any conversation after the auto accident,
please state the content of any such conversation.
If any members of your family or anyone else had any conversations
with the Plaintiff, please state to the best of your knowledge the
place of such conversations and the nature and content of such
Steven Williams, Attorney
State Bar No. 12345
Attorneys for Plaintiff
45 Spellman Street
Decatur, GA 30030
CERTIFICATE OF SERVICE
This is to certify that I, Steven Williams, have this day served all
parties in the foregoing matter with a copy of the within and
foregoing Defendant’s First Continuing Interrogatories to Defendant,
by depositing copies of the same in the United States Mail in a
properly addressed envelope with adequate postage thereon to:
9054 Messina Lane
Decatur, GA 30030
This 20th day of December, 2009.