Kentucky Interrogatories and Requests for Production — Personal Injury In a personal injury case in Kentucky, the legal process may involve the use of interrogatories and requests for production. These tools allow both parties involved in the lawsuit to gather necessary information, facts, and evidence from each other relevant to the case. By issuing interrogatories and requests for production, the attorneys aim to build their respective arguments, investigate claims and defenses, and ensure a fair and just trial. Interrogatories are written questions that one party sends to the other, and the receiving party must answer truthfully and accurately under oath. These questions cover various aspects of the personal injury case, such as details of the incident, injuries sustained, medical history, previous accidents, and any other relevant information. Interrogatories help create a comprehensive understanding of the case by eliciting specific facts, determining liability, and assessing the damages suffered. Meanwhile, requests for production are formal demands to obtain specific documents, records, or tangible items related to the personal injury claim. This could include medical records, accident reports, insurance policies, photographs, video footage, and any other relevant evidence. By requesting production, the party seeks to acquire evidence that supports their case or weakens the opposing party's position. Some common types of Kentucky Interrogatories and Requests for Production in personal injury cases may include: 1. Interrogatories: — Interrogatories related to liability: These questions focus on gathering information about the circumstances leading up to the injury, the actions or negligence of the other party, and any contributing factors to the incident. — Interrogatories related to damages: These queries seek to uncover the extent of the injuries suffered, medical treatments received, loss of income, pain and suffering, future medical needs, and other relevant information that can determine the damages claimed by the injured party. — Interrogatories related to witnesses: These interrogatories aim to identify potential witnesses to the incident and gather their testimonies or statements regarding the events that occurred. 2. Requests for Production: — Medical records and bills: These requests seek all medical records, including hospital stays, surgeries, consultations, prescriptions, and any other documents that pertain to the injuries sustained. — Employment records: These requests aim to obtain employment-related documents such as pay stubs, tax returns, and other records to support claims of lost wages or diminished earning capacity. — Insurance policies: These requests seek to obtain copies of insurance policies held by either party involved, including health insurance, automobile insurance, and homeowner's insurance policies. — Photographs and videos: These requests demand the production of any photographs, videos, or surveillance footage related to the incident that may provide visual evidence supporting either party's claims. Overall, Kentucky Interrogatories and Requests for Production are crucial elements of the discovery process in a personal injury case. Through these tools, attorneys can gather essential facts, evidence, and documentation to support their client's position and help secure a fair and just resolution of the case.
Kentucky Interrogatories and Requests for Production - Personal Injury
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The grounds for objecting to an interrogatory must be stated with specificity. Any ground not stated in a timely objection is waived unless the court, for good cause, excuses the failure. (5) Signature. The person who makes the answers must sign them, and the attorney who objects must sign any objections.
If your case is an unlimited civil case (over $25,000) you may ask up to 35 special interrogatories, but may ask more with a declaration explaining the need for additional requests and a statement that the request is not done for an improper purpose.
You can object to an interrogatory if the information sought is known by the requesting party or available to both parties equally. For example, you should raise this objection if the answers are publicly available or in a third-party's custody or control.
These are typically requests that are not relevant, unduly burdensome, broad, vague, privileged. or protected by the work product doctrine.
Common objections to requests for production or inspection include: The request is overly broad or unduly burdensome. ... The request is vague, ambiguous, or unintelligible. ... The request is not reasonably calculated to lead to the discovery of relevant, admissible evidence.
You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.
Rule 33(d) states that a party electing to respond to an interrogatory by providing electronically stored information must ensure that the interrogating party can locate and identify it ?as readily as can the party served,? and that the responding party must give the interrogating party a ?reasonable opportunity to ...