IN THE UNITED STATES DISTRICT COURT

FOR THE CENTRAL DISTRICT OF ILLINOIS

JUSTIN WILLIAM KING, )

)
Plaintiff. )
) Civil Action No. 11-CIV-012345
)
v. )
)
ANHEUSER-BUSCH COMPANIES, INC. ) Judge Julie James
)
Defendant. )
____________________________________)

FIRST SET OF INTERROGATORIES TO DEFENDANT ANHEUSER-BUSCH

To: Defendant Anheuser-Busch and its attorney, John Smith, 234 Main Street, Chicago, IL 60601

PLEASE TAKE NOTICE that plaintiff Justin King demands answers to the following
interrogatories, under oath, pursuant to Rule 33 of the Federal Rules of Civil Procedure.

1. If you contend that the falling cargo was not the cause of the accident, please provide a
concise statement of facts which you base your contention.
2. Please state your companys policies in regards to the length of time a driver is allowed
on the road.
a) Please provide your itinerary prior to and including the date of the auto accident.
b) Can you please provide a copy of the drivers log?
c) Please include any stops made and the length of time at each place.
d) Please provide a detailed account of whom you spoke to at each location.
3. Please provide your company's maintenance records, if any, that was performed on the
vehicle in the last six (six) months prior to the accident. For each maintenance
performed, please list the following:
a) Cause or reason for maintenance?
b) Name of individual who performed the maintenance?
c) Date repairs were performed?
d) What parts were replaced, if any?
e) Was this a reoccurring issue? If so, when?
4. Please provide the names, area of expertise, and summary of the expected testimony for
each expert witness who will be called at the trial of this case.
 5. Please provide a list of all accidents for Defendant and agents for Defendant within the
past five (5) years. Please also provide the following:
a) Name and address of any driver for all vehicles involved?
b) The court case number of any action that resulted?
c) The result of each action?

Dated:

Jane Doe
IL Attorney License # 12345
Law Office of Jane Doe
123 Main Street
Chicago, IL 60601

Attorney for Plaintiff