Plaintiffs Approved Interrogatories Directed To Defendant

IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS STATE OF MISSOURI___________________, ) ) Plaintiff, ) ) Cause No. _______________ Vs. ) ) Division No. __________________________, ) ) Defendant. ) PLAINTIFFS APPROVED INTERROGATORIES DIRECTED TO DEFENDANT Comes now plaintiff, by and through plaintiffs attorney of record, pursuant toRule 32.2.2 of the Local Rules of the Circuit Court of the Twenty-Second JudicialCircuit and propounds the following Interrogatories to defendant to be answeredin writing, under oath, within the time provided by the Missouri Rules of CivilProcedure: 1. Please state the date that plaintiff was first employed by defendant and set forth all periods of plaintiffs absences from work (other than rest days, vacation and holidays) since the date of the occurrence alleged in plaintiffs Petition. ANSWER: 2. For each preemployment physical examination, return to work physical examination special examination or any other employment related physical examination or evaluation of plaintiff while plaintiff was employed by defendant state: (a) The name and address of the physician performing the examination; and (b) The date of the examination. ANSWER: <<<<<<<<<********>>>>>>>>>>>>> 2 PLAINTIFFS APPROVED FELA INTERROGATORIES TO DEFENDANT 3. Set forth and describe the physical restrictions, if any, defendant imposed upon plaintiff with regard to plaintiff performing work of plaintiffs craft within three (3) years prior to the date of the occurrence alleged in plaintiffs Petition. ANSWER: 4. Did defendant impose any physical limitations or restrictions upon plaintiff with regard to plaintiff performing the work of plaintiffs craft for defendant at any time after the date of the occurrence alleged in plaintiffs Petition? If so, set forth in detail and to the best of defendants ability the nature of and content of the limitations or restrictions and when they were in effect. ANSWER: 5. Do defendants records indicate that plaintiff every sustained injuries while employed by defendant? If so, state the following: (a) The date or dates of the injures. (b) The nature of the injuries. (c) Did defendant authorize or permit plaintiff to return to work subsequent to the injuries? If so, state the following: (1) The names and addresses of the persons who participated in making the decision permitting or authorizing plaintiff to return to work. (2) The date or dates the permission or authorization was given. (3) Are there any documents with regard thereto? If so, (i) State the name and address of the person having possession, custody or control of those documents. ANSWER: 2<<<<<<<<<********>>>>>>>>>>>>> 3 PLAINTIFFS APPROVED FELA INTERROGATORIES TO DEFENDANT 6. Please set forth and describe any disability, injury, illness, disease or symptomatology plaintiff experience while employed by defendant prior to the occurrence alleged in plaintiffs Petition. ANSWER: 7. Identify by name and address the physicians, chiropractors, clinics, hospitals and/or medical care providers from whom defendant has received any reports, writings, written correspondence or memoranda regarding any examination or treatment concerning this plaintiff. ANSWER: 8. State the name and address of plaintiffs direct foreman or supervisor on the date of the occurrence alleges in plaintiffs Petition. ANSWER: 9. Have any motion pictures, videotape recordings or photographs of plaintiff been taken by you or anyone acting on your behalf: If so, state for each: 3<<<<<<<<<********>>>>>>>>>>>>> 4 PLAINTIFFS APPROVED FELA INTERROGATORIES TO DEFENDANT (a) The date(s) each photograph, videotape recording or motion picture was taken; (b) The name and address of each person taking the photograph, videotape recording or motion picture; (c) The location where each photograph, videotape recording or motion picture was taken; and (d) The present location of each photograph, videotape recording or motion picture. ANSWER: 10. Identify all persons who have followed and in any way conducted surveillance of the plaintiff on behalf of the defendant since the date of the incident(s) described in plaintiffs Petition. For each such person: (a) State the name and address of the person; (b) State under whose direction the person was acting; and (c) State the date and location where the surveillance was conducted. ANSWER: 11. State the names, addresses and occupations of any and all individuals known to defendant, its representatives, or its attorneys, to have been present at the scene of the occurrence alleged in plaintiffs Petition within one hour before, at the time of, or within one hour after the occurrence. ANSWER: 12. State the name, address and occupation of any person known to defendant, its representatives, or its attorneys, to have witnessed the occurrence alleged in plaintiffs Petition. ANSWER: 4<<<<<<<<<********>>>>>>>>>>>>> 5 PLAINTIFFS APPROVED FELA INTERROGATORIES TO DEFENDANT 13. Describe in detail and to the best of defendants ability the work or employment duties that defendant assigned plaintiff to perform at the time of the occurrence alleged in plaintiffs Petition. Also, state the following: (a) Does defendant have any documents setting forth those assigned duties? (1) If so, state the name and address of the person having possession of those documents. ANSWER: 14. State the name, job title or position and address of each and every person (including foremen and supervisors) who were assigned to work with plaintiff at the time of the occurrence alleged in plaintiffs Petition. ANSWER: 15. If defendant communicated any warning to plaintiff about using the (PIECE OF EQUIPMENT) plaintiff was working with at the time of the alleged occurrence, describe in detail and to the best of this defendants ability the content of such warning and the name of the person who communicated the warning to plaintiff. ANSWER; 5<<<<<<<<<********>>>>>>>>>>>>> 6 PLAINTIFFS APPROVED FELA INTERROGATORIES TO DEFENDANT 16. During the 3 years prior to the incident referred to in plaintiffs Petition, did defendant hold or conduct any safety meetings with members of plaintiffs craft at (WORK LOCATION)? (a) If hour answer is yea, does defendant have any records, minutes or notes pertaining to those meetings? (1) If so, state the name and address of the person having possession of those records, minutes or notes. ANSWER: 17. During the 3 years prior to the incident referred to in plaintiffs Petition, did defendant perform any routing safety audits or routine