DISTRODUCT FOR THE CIRECT AT MEMPHIS
IN THE CIRCUIT COURT OF TENNESSEE
FOR THE THIRTIETH JUDICIAL DISTRICT AT MEMPHIS
LATOYA DOTSON and DERRICK DOTSON, SR., Individually and as legal guardians of minors, JAMES WILLIAMS and DERRICK DOTSON, JR.,
Plaintiff(s),
vs.
NAHTAN TAT, DOUGLAS TAT, AND JESSICA TAT
Defendant(s).
Docket No. CT-001833-14
DIV II
DEFENDANTS’ FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO PLAINTIFFS
TO:
Nathan Tat, Douglass Tat, AND Jessica Tat c/o Christopher Sobczak, (25704)
Attorney for Defendant, Nathan Tat
4515 Poplar Avenue, Suite 329
Memphis, TN 38117
Defendant submits the following Interrogatories pursuant to the Tennessee Rules of Civil Procedure, to …show more content…
Have you ever received any money, whether by settlement, trial, insurance payment or otherwise, for any personal injury? If so, as to each, describe the injury, the amount of payment made, the approximate date or dates. Attach copies of any documents in the possession of you or your attorney pertaining to such claims and payments.
ANSWER:
9. Has any physician or other practitioner of the healing arts ever evaluated you for disability or for impairment in connection with any injury or condition? If so, provide the name and address of the physician, the approximate date of the evaluation, and the disability of impairment assigned, if any. Attach copies of any written reports or records of such evaluations in the possession of you or your attorney. ANSWER: 10. Apart from the present civil action, has any other civil action ever been filed on your behalf against anyone? If so, as to each, explain briefly the nature of the action, the county and state in which it was filed, approximately when it was filed, and the name and address of the attorney who represented you or is representing you. ANSWER: …show more content…
ANSWER:
27. Itemize and explain in detail any claim you made in this action for financial loss or damage which has not been explained in answer to questions above. ANSWER: 28. Fully describe each and every way in which you have been adversely affected by this accident, including but not limited to pain and suffering and the parts of your body affected thereby, loss of enjoyment of life, permanent injury, disfigurement or impairment, loss of mental faculties or capacity, impairment of earning capacity, and modification or cessation of activities. ANSWER:
29. Have you ever been charged with, convicted of, or plead guilty to a crime? As to each instance, state the date of the offense, the nature of the offense, the county and state where the offense occurred and the ultimate disposition of the matter. ANSWER: No
REQUESTS FOR PRODUCTION OF DOCUMENTS
1. Copies of all medical bills alleged to have been incurred for treatment of injuries sustained in this accident.
FOR THE THIRTIETH JUDICIAL DISTRICT AT MEMPHIS
LATOYA DOTSON and DERRICK DOTSON, SR., Individually and as legal guardians of minors, JAMES WILLIAMS and DERRICK DOTSON, JR.,
Plaintiff(s),
vs.
NAHTAN TAT, DOUGLAS TAT, AND JESSICA TAT
Defendant(s).
Docket No. CT-001833-14
DIV II
DEFENDANTS’ FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO PLAINTIFFS
TO:
Nathan Tat, Douglass Tat, AND Jessica Tat c/o Christopher Sobczak, (25704)
Attorney for Defendant, Nathan Tat
4515 Poplar Avenue, Suite 329
Memphis, TN 38117
Defendant submits the following Interrogatories pursuant to the Tennessee Rules of Civil Procedure, to …show more content…
Have you ever received any money, whether by settlement, trial, insurance payment or otherwise, for any personal injury? If so, as to each, describe the injury, the amount of payment made, the approximate date or dates. Attach copies of any documents in the possession of you or your attorney pertaining to such claims and payments.
ANSWER:
9. Has any physician or other practitioner of the healing arts ever evaluated you for disability or for impairment in connection with any injury or condition? If so, provide the name and address of the physician, the approximate date of the evaluation, and the disability of impairment assigned, if any. Attach copies of any written reports or records of such evaluations in the possession of you or your attorney. ANSWER: 10. Apart from the present civil action, has any other civil action ever been filed on your behalf against anyone? If so, as to each, explain briefly the nature of the action, the county and state in which it was filed, approximately when it was filed, and the name and address of the attorney who represented you or is representing you. ANSWER: …show more content…
ANSWER:
27. Itemize and explain in detail any claim you made in this action for financial loss or damage which has not been explained in answer to questions above. ANSWER: 28. Fully describe each and every way in which you have been adversely affected by this accident, including but not limited to pain and suffering and the parts of your body affected thereby, loss of enjoyment of life, permanent injury, disfigurement or impairment, loss of mental faculties or capacity, impairment of earning capacity, and modification or cessation of activities. ANSWER:
29. Have you ever been charged with, convicted of, or plead guilty to a crime? As to each instance, state the date of the offense, the nature of the offense, the county and state where the offense occurred and the ultimate disposition of the matter. ANSWER: No
REQUESTS FOR PRODUCTION OF DOCUMENTS
1. Copies of all medical bills alleged to have been incurred for treatment of injuries sustained in this accident.