IN THE SUPERIOR COURT OF THE STATE OF ARIZONA

IN AND FOR THE COUNTY OF MARICOPA

Alice Bates, et al Plaintiff(s)

v.

Gayle Stewart Trucking Company

Defendant(s) )
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Civil Action No. 2017-92343

INTERROGATORIES

Assigned to the Honorable
JOSEPH CANTON

TO: Plaintiff

Pursuant to Rule 33 of the Arizona Rules of Civil Procedure, Alice Bates, et al hereby demands that Gayle Stewart Trucking Company answer in writing and under oath within 40 days from the receipt hereof the following Interrogatories:

FIRST SET OF UNIFORM INTEROGATTORIES TO PLAINTIFF

INSTRUCTIONS FOR USE

A. All information is to be divulged which is in the possession of the individual or corporate party, his attorneys, investigator, agents, employees, …show more content…
Rate of pay or compensation received.

Interrogatory No. 15: Do you claim that your ability to engage in any type of gainful employment has been affected by the accident? ___ If so, state:
A. The specific condition which limits your ability to engage in gainful employment.
B. The economic loss caused by your inability to find gainful employment.
C. Your method of computation for computing such loss.

Interrogatory No. 16: Provide the identity and location of any nonparty identified in your response to Interrogatory No. 5 above, who you claim, pursuant to A.R.S. § 12-2506(B) (as amended), was wholly or partially at fault in causing any personal injury, property damage, or wrongful death for which damages are sought in this action.

Interrogatory No. 17: Do you have liability insurance or are you aware of any other form of indemnity which you claim is applicable to this accident? ___ If the answer is yes, state:
A. The name of the company or companies, including any excess or umbrella carriers, which you claim provide coverage.
B. The policy number or numbers of any applicable policy.
C. The limit or limits of liability of each policy.
D. The named insured on each policy.
E. Whether the insurance carrier has accepted or denied …show more content…
18: State the name, address, and occupation of the owner of any vehicles you allege caused damage to the plaintiff.

Interrogatory No. 19: At the time of the alleged accident, was the driver of said vehicle engaged in the business of any other person or entity? ___ If so, please state the name and address of such other person or entity.

Interrogatory No. 20: State whether you or anyone else involved in the accident ingested or used any drugs or medications within 48 hours prior to the accident or drank any intoxicating beverages of any kind within the 12 hours prior to the accident or to the occurrence of the accident alleged in the Complaint. ___ If so, state the times, places, amount, and type of drugs or alcoholic beverages.

Interrogatory No. 21: Do there exist any liens, including AHCCCS, Medicare, or any liens provided for by A.R.S. § 33-931 et seq., on any recovery you may have or may obtain in this matter? ___ If so, give the amount and entity holding such lien and the nature of said lien.

Interrogatory No. 22: If the accident that is the subject of the plaintiff's claim was an automobile accident, please state the