text:"These requests are continuing in character and require you to file supplementary or amended responses if you obtain further, different or contradictory information at any time prior to a trial of this action.",
text:"These requests are continuing in nature and require you to file supplementary or amended responses if you obtain further, different or contradictory information at any time prior to a trial of this action.",
},
},
{
{
id:"17822ae2-d8ae-4d76-aff6-2c0740d7ba0e",
id:"17822ae2-d8ae-4d76-aff6-2c0740d7ba0e",
text:"Unless otherwise stated, these requests refer to the time, place, and circumstances of the occurances described and/or complained of in the Complaint and which form the basis for this action.",
text:"Unless otherwise stated, these requests refer to the time, place, and circumstances of the occurrences described and/or complained of in the Complaint and which form the basis for this action.",
text:"'You' refers to the party to whom the requests are addressed and any addiitonal parties or entities as described in the foregoing instructions and these definitions.",
text:"'You' refers to the party to whom the requests are addressed and any additional parties or entities as described in the foregoing instructions and these definitions.",
text:" Identify all insurance carriers or self-insured funds, by name, address, policy numbers and policy limits, for any insurance policy or fund which may provide coverage for any judgment entered against you related to this occurrence.",
text:" Identify all insurance carriers or self-insured funds, by name, address, policy numbers and policy limits, for any insurance policy or fund which may provide coverage for any judgment entered against you in this action.",
},
},
{
{
id:"72680c6f-4d7e-4e6b-a932-477e0392db98",
id:"72680c6f-4d7e-4e6b-a932-477e0392db98",
text:" If you contend that any other entity or person, including any other party or the Plaintiff, was responsible for the occurrence and Plaintiff’s injuries, identify such person(s) or entities, and give a concise statement of the facts upon which you rely in support of your contention.",
text:" If you contend that any other entity or person, including any other party or the Plaintiff, was responsible for the occurrence and Plaintiff's damages, identify such person(s) or entities, and give a concise statement of the facts upon which you rely in support of your contention.",
},
},
{
{
id:"6933ce23-8c88-4c6b-877c-c59629685ea1",
id:"6933ce23-8c88-4c6b-877c-c59629685ea1",
@@ -88,7 +88,7 @@ export const foundationRogs = [
},
},
{
{
id:"e2c7bb8d-48cf-47e9-b27d-e872dcffdd3d",
id:"e2c7bb8d-48cf-47e9-b27d-e872dcffdd3d",
text:"Describe any conduct, comment, conversation, statement, or report made by the Plaintiff or any other person, at the scene of the occurrence or at any time, concerning fault for the occurrence or facts relevant to any issue in this case. Include in your answer where the conduct, comment, conversation, or statement took place, and in whose presence it was made/observed, as well as the name of the author of such statement, the present custodian of the statement and the address for the custodian.",
text:"Describe any conduct, comment, conversation, statement, or report made by any person at the scene of the occurrence or at any time, concerning fault for the occurrence or facts relevant to any issue in this case. Include in your answer where the conduct, comment, conversation, or statement took place, and in whose presence it was made/observed, as well as the name of the author of such statement, the present custodian of the statement and the address for the custodian.",
},
},
{
{
id:"4c3ffbf0-6259-4f43-8996-bdb25e6203a7",
id:"4c3ffbf0-6259-4f43-8996-bdb25e6203a7",
@@ -96,7 +96,7 @@ export const foundationRogs = [
},
},
{
{
id:"4c3ffbf0-6259-4f43-8996-bdb25e6203a7",
id:"4c3ffbf0-6259-4f43-8996-bdb25e6203a7",
text:"If you are aware of any other case or proceeding involving the incident identified in Plaintiff's Complaint including, but not limited to, civil, criminal or administrative actions, identify the case or action by tribunal, case number, docket number or citation number, the date of any hearing, and indicate any pleas in the case(s) and the disposition of the matter(s).",
text:"If you are aware of any other case or proceeding involving the occurance identified in the Complaint including, but not limited to, civil, criminal or administrative actions, identify the case or action by tribunal, case number, docket number or citation number, the date of any hearing, and indicate any pleas in the case(s) and the disposition of the matter(s).",
},
},
];
];
@@ -143,7 +143,7 @@ export const standardProd = [
},
},
{
{
id:"cdcc44cf-13b2-4011-adb5-ed435156a0f8",
id:"cdcc44cf-13b2-4011-adb5-ed435156a0f8",
text:"Any documents which afforded, descirbed or pertained to liability insurance coverage for the occurrences which are the subject matter of the complaint.",
text:"Any documents which afforded, described or pertained to liability insurance coverage for the occurrences which are the subject matter of the complaint.",
index:8,
index:8,
},
},
{
{
Reference in New Issue
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