Defendants Approved Fela Interrogatories To Plaintiff

DEFENDANTS APPROVED FELA INTERROGATORIES TO PLAINTIFF IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS STATE OF MISSOURI___________________, ) ) Plaintiff, ) ) Cause No. __________ vs. ) ) Division No. ________________________, ) ) Defendant. ) DEFENDANTS APPROVED FELA INTERROGATORIES TO PLAINTIFF COMES NOW defendant pursuant to Local Court Rule 32.2.2, and herebypropounds the following approved Interrogatories to plaintiff to be answered inwriting, under oath within the time provided by the Missouri Rules of CivilProcedure: 1. State your full name, any other names by which you have been known, present residence address, social security number, and place and date of birth. ANSWER: 2. List all addresses at which you have resided for the last 10 years, stating inclusive dates for each such address. ANSWER: 3. State whether you are married at the present time? If so, state: (a) your spouses full name; (b) the date and place of your marriage; (c) the number of children and the name and age of each child;<<<<<<<<<********>>>>>>>>>>>>> 2 DEFENDANTS APPROVED FELA INTERROGATORIES TO PLAINTIFF (d) which of these children is dependent on you for support and the amount of support; (e) whether your spouse is now living with you; (f) if not, when the separation occurred; if you are legally divorced, the date and place of said divorce; (g) your spouses present address. ANSWER: 4. State whether you were previously married, and, if so, for each previous spouse state: (a) the present name and present residence address of each spouse; (b) the dates of the commencement and termination of each marriage; (c) the place where you were married to each spouse; (d) for each marriage, the manner in which it was terminated; (e) if any marriage was terminated by divorce, for each such divorce, the county and state or place where the action was filed and the date when the divorce was granted; (f) whether any children of past marriages are dependent upon you for support, and if so, list the childrens names and the amount of support. ANSWER: 5. For all employment preceding and up until the date of any incident referred to in this lawsuit, state; (a) the names and addresses of each of your employers; (b) the dates of commencement and termination of each such employment and the reason for termination; (c) your job title and a description of the services or work performed by you for each such employment; 2<<<<<<<<<********>>>>>>>>>>>>> 3 DEFENDANTS APPROVED FELA INTERROGATORIES TO PLAINTIFF (d) the average number of hours you worked per week; (e) your average gross weekly wages or earnings from each such employment; (f) for each employer, whether a physical examination was required and, of so, the date, place and person performing the physical examination; (g) for each employment, whether light, medium or heavy physical activity was required; (h) for each employer, whether or not you made any representations in writing or answers in writing concerning your physical condition or health; (i) the name of your immediate boss, foreman, or other supervisor to whom you were responsible for each employment listed above. ANSWER: 6. Have you returned to active duty at the railroad since the incident referred to in this lawsuit: If so, state: (a) the first date you returned to work and the name of the person who authorized you to do so; (b) the dates of all active duty since the incident referred to in your Petition; (c) for the dates listed in 6(b), state the type of job you have performed, and whether you worked at full duty or restricted duty; if both, give the dates for each; (d) if you are not now working active duty for the railroad, please state why you are not so working (i.e., medical leave, furlough, resigned, terminated, new employment). ANSWER: 3<<<<<<<<<********>>>>>>>>>>>>> 4 DEFENDANTS APPROVED FELA INTERROGATORIES TO PLAINTIFF 7. If you have been employed in some capacity other than the railroad after the incident referred to in this lawsuit, state the following: (a) the names and addresses of each of your employers; (b) the dates of each such employment; (c) a description of the services or work performed by you for each such employment; (d) your average gross weekly wages or earnings from each such employment; (e) for each employer, state whether a physical examination was required and, if so, the date, place and person performing the physical examination; (f) for each employment, state whether light, medium or heavy physical activity was required; (g) for each employer, state whether you made any representations in writing or answers in writing concerning your physical condition or health; (h) the name of your immediate boss, foreman, or other supervisor to whom you were responsible for each employment listed above; (i) if you are no longer working in any employment, please state the reason. ANSWER: 8. Have you ever applied for or received RRB benefits, Supplemental Sickness benefits, Social Security benefits, or disability pension benefits? If so, with respect to each, state: (a) the type of benefit and the name and address of the office with whom you applied for such benefit; (b) the date you applied for such benefit; (c) whether you were awarded such benefits; (d) the condition for which you received such benefits. ANSWER: 4<<<<<<<<<********>>>>>>>>>>>>> 5 DEFENDANTS APPROVED FELA INTERROGATORIES TO PLAINTIFF 9. State whether you have ever filed a workers compensation claim and, if so, with respect to each claim, state: (a) the date the claim was filed; (b) the state in which the claim was filed and the number of the claim; (c) the name of the employer against whom you made the claim. ANSWER: 10. If you are making a claim for past or future wage loss or loss of earning capacity, and if you are unable to produce tax returns, with respect to your income during each of the past five calendar years, please state: (a) your yearly gross income; (b) your yearly net income; (c) the name and address of any tax preparer or other person, firm or corporation having custody of any papers pertaining to your income; (d) whether you have filed any state or federal income tax returns in the past five years and, if so, give the address of the Internal Revenue Service office and any state tax authority with whom you have filed income tax returns and the year in which returns were filed with each such authority. ANSWER: 11. State the name and address of each junior high school, high school, vocational or technical school,