SAMPLE LETTER FOR TRIAL — DEFENDANT'S FIRST INTERROGATORIES TO PLAINTIFF (WISCONSIN) [Your Name] [Your Address] [City, State, ZIP Code] Email: [Your Email] Phone: [Your Phone Number] Date: [Date] [Plaintiff's Name] [Plaintiff's Address] [City, State, ZIP Code] Re: Case No. [Case Number] [Title of the Case] Dear [Plaintiff's Name], I hope this letter finds you well. Pursuant to the Wisconsin Rules of Civil Procedure, specifically Rule 804.08, and to facilitate a fair and efficient trial, the Defendant requests that you provide written responses to the following interrogatories within 30 days from the receipt of this letter. These interrogatories seek information relevant to the issues presented in this case. Please carefully review each interrogatory and provide complete and detailed responses under oath. If any question is not applicable, indicate so accordingly. In case any response relies upon documents, please attach copies as exhibits. Please number your responses corresponding to each interrogatory. Interrogatory 1: Please provide a detailed description of the incident that forms the basis for your claim against the Defendant. Include all the circumstances, events, dates, and individuals involved to the best of your knowledge. Interrogatory 2: Identify all witnesses, including their names, addresses, and phone numbers, who have any knowledge or information regarding the incident mentioned in your complaint, or any other aspect related to this case. Interrogatory 3: State the names, addresses, and phone numbers of any experts the Plaintiff intends to call as witnesses and provide a detailed summary of their areas of expertise and the opinions they will offer. Additionally, provide a copy of any written reports prepared by the experts relating to this case. Interrogatory 4: Provide a complete list of all medical providers and healthcare facilities you have consulted or been treated by, including names, addresses, dates of treatment, and a brief summary of the diagnosis, treatment received, medications prescribed, and expenses incurred attributable to the injuries claimed. Interrogatory 5: Identify any previous accidents, injuries, or claims for damages involving you, whether as a plaintiff, defendant, or otherwise, within the past ten (10) years. Interrogatory 6: Please provide a list of all documents, records, photographs, videos, or any other tangible evidence that you possess or have access to that supports your claims in this case. Please specifically itemize and describe each piece of evidence. Interrogatory 7: Identify all insurance policies under which you or your legal representatives may seek compensation for the claims made in this lawsuit. Provide the name of the insurance company, policy number, and a description of the coverage. Please be advised that failure to respond to these interrogatories within the stipulated timeframe may result in adverse inferences being made at trial or potential sanctions, as permitted under the Wisconsin Rules of Civil Procedure. Thank you for your prompt attention to these interrogatories. Should you require any clarification or have any questions regarding these interrogatories, please do not hesitate to contact me directly. Yours sincerely, [Your Name] [Your Title/Position] [Law Firm Name] [Law Firm Address] [City, State, ZIP Code] Email: [Your Email] Phone: [Your Phone Number]
Wisconsin Sample Letter for Trial - Defendant's First Interrogatories to Plaintiff
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They are provided for your information. There is no form for your answer, but you typically have to respond in a specified format, using paper with numbers down the left-hand side, with your name and address at the top left, the name of the court and of the case, and the case number.
These go into your trial notebook. In most jurisdictions, interrogatory answers can be introduced by reading them to the jury. A party's interrogatory's answers can also be used to impeach the party's in-court testimony. As an admission, the answers will generally be an exception to the hearsay rule.
Interrogatories and the answers to interrogatories are generally not admissible as evidence in court. However, the information that is revealed through interrogatories can be used to prepare for trial and to identify potential witnesses or evidence that may be introduced at trial.
2030.020. (a) A defendant may propound interrogatories to a party to the action without leave of court at any time. (b) A plaintiff may propound interrogatories to a party without leave of court at any time that is 10 days after the service of the summons on, or appearance by, that party, whichever occurs first.
Answer only the question that is asked, and avoid the temptation to over-explain your answer. If the question contains several parts, you may break your answer into parts as well. It is also possible that you might object to the question.
In civil procedure, an interrogatory is a list of written questions one party sends to another as part of the discovery process. The recipient must answer in writing under oath and ing to the case's schedule.
Interrogatories are lists of questions sent to the other party that s/he must respond to in writing. You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.
How to Write Draft Interrogatories Brainstorm questions to ask the non-party related to the issues in the case. Identify relevant documents, witnesses, or other evidence that will be needed to answer the interrogatories. Draft the interrogatories in written form. Ensure the interrogatories are clear, concise and specific.
