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Below are sample interrogatory questions propounded in a typical car accident lawsuit. Defendant. ) PLAINTIFF'S FIRST INTERROGATORIES DIRECTED TO DEFENDANT.Comes now plaintiff, and in accordance with the Missouri Rules of Civil Procedure,. Defendants Approved Auto Accident Interrogatories To Plaintiff. PDF Download Download Free Print-Only PDF OR Purchase Interactive PDF Version of this Form. Plaintiffs Approved Auto Accident Interrogatories To Defendant. State your full name, your present address, and date of birth. Ans. 2. Defendant's Court Approved Non-Standard Interrogatories and Requests to Produce. Defendant. OPENING INTERROGATORIES TO INDIVIDUAL DEFENDANT IN VEHICULAR NEGLIGENCE PERSONAL INJURY OR PROPERTY DAMAGE CASES ONLY. NAME. 1. Sample 213 Interrogatories to Defendant in a Motor Vehicle Accident.