Wake North Carolina Plaintiff's First Set of Interrogatories and Requests for Production of Documents to Defendant is a legal document commonly used in the pre-trial discovery phase of a civil lawsuit. It is typically served by the plaintiff to the defendant, requesting specific information and documents related to the case. Here are some key details and types of interrogatories and document requests that the plaintiff might include: 1. General Introduction: The Wake North Carolina Plaintiff's First Set of Interrogatories and Requests for Production of Documents will often begin with a general introduction, outlining the purpose and scope of the document. 2. Identification and Background Information: The plaintiff might seek basic information about the defendant, such as their name, address, employment history, and any previous legal actions they have been involved in. 3. Specific Claims and Allegations: The plaintiff may ask the defendant to provide a detailed response to the specific claims and allegations made in the lawsuit. This could include questions about events leading up to the incident, the defendant's actions, and any potential negligence or wrongdoing. 4. Witnesses and Evidence: Interrogatories and document requests may ask the defendant to identify any witnesses they plan to call at trial, along with their contact information. The plaintiff may also request copies of any documents or evidence the defendant plans to use to support their defense, such as photographs, videos, or medical records. 5. Financial Information: The plaintiff might inquire about the defendant's financial situation, including information about their income, assets, and insurance coverage. This information may be relevant for assessing potential damages and ensuring the defendant can satisfy any judgment that may be awarded. 6. Expert Witnesses: In certain cases, the plaintiff may include interrogatories and requests for production related to any expert witnesses that the defendant intends to call. This may include their qualifications, prior testimony, and copies of any reports or opinions they have provided. It is important to note that the specific content and structure of the Wake North Carolina Plaintiff's First Set of Interrogatories and Requests for Production of Documents can vary depending on the nature of the case and the preferences of the plaintiff's attorney. Therefore, it is always advisable to consult with legal professionals to ensure compliance with local rules and best practices.