IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

 

                                                                                    }         

RYAN CHRISTIANSON,                                          }

                                                                                    }                                 

                                    Plaintiff,                                    }

                                                                                    }          No.  04 CV 123321

v.                                                                                 }

                                                                                    }

BICYCLE MESSENGERS, INC and              }

YOMAHONDA, INC                                                 }

                                                                                    }

                                    Defendant.                                }

                                                                                    }

 

INTERROGATORIES TO DEFENDANT, BICYCLE MESSENGERS, INC.

 

1.  Please state, in respect to the Plaintiff’s employment by Bicycle Messengers, Inc., the exact date that the Plaintiff was hired, the Plaintiff’s position and the date that the Plaintiff was discharged.

 

2.  Please state, in detail, the duties required by the Plaintiff while performing under this position.

 

3.  Please state the names, addresses and phone numbers of all Bicycle Messengers, Inc employees who have been discharged within the last 5 years.

 

4.  Have you, or anyone acting on your behalf, tested the Plaintiff’s ability to perform under the duties of his position?

 

5.  Have any of your past or current employees filed any lawsuit against you within the last 5 years?  If yes, please provide the case number, year of filing and the result of such lawsuit.

 

6.  State your defenses to this lawsuit and all facts that support or may tend to support each of the defenses.

 

7.  Identify all persons who have knowledge of facts which support or may tend to support your defense(s) and provide a summary of the facts or information in each person's possession which supports or may tend to support your defense(s).

 

8.  Please identify any past or present employees that have been disabled, listing specifically the disability of such employees.


IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

 

                                                                                    }         

RYAN CHRISTIANSON,                                          }

                                                                                    }                                 

                                    Plaintiff,                                    }

                                                                                    }          No.  04 CV 123321

v.                                                                                 }

                                                                                    }

BICYCLE MESSENGERS, INC and              }

YOMAHONDA, INC                                                 }

                                                                                    }

                                    Defendant.                                }

                                                                                    }

 

INTERROGATORIES TO DEFENDANT, YOMAHONDA, INC.

 

1.  State the name and address of any person, firm or entity that designed, assembled, distributed, advertised and serviced the subject vehicle.

 

2.   State whether you intend to assert any defenses at the time of trial.

 

3.  If the answer to Interrogatory number 2 is in the affirmative, and your defense is based upon an alteration, use, misuse of or other change in the vehicle, indicate each such defense and fully provide the factual basis for any such defense.

 

4.  State whether at any time prior to answering these interrogatories and subsequent to the date of manufacturing or distribution of the vehicle itself any person complained or alleged that he, she or anyone else suffered bodily injuries or death as a result of using the vehicle in the manner in which Plaintiff claims to have used the vehicle when the injury occurred.

 

5.  If any lawsuits resulted form the above mentioned complaints or allegations list the year of filing, the case number, the state where the suit was filed, and the result of such lawsuit.

 

5.  If you allege that any other person or vehicle is responsible for the injuries sustained by the Plaintiff list the name, address, and phone number of such persons or manufacturers.