IN THE SUPERIOR COURT OF THE STATE OF DELAWARE NEW CASTLE COUNTY
XYZ Name
123 Generic Street
New Castle, DE 19720
Plaintiff
vs.
XYZ Company
123 Generic Street
New Castle, DE 19720
and
XYZ Company
123 Generic Street
New Castle, DE 19720
and
XYZ Company, LLC
123 Generic Street
New Castle, DE 19720
and
XYZ Name
Individually and as an Agent of the
Co-Defendant XYZ Company
123 Generic Street
New Castle, DE 19720
and
OFFICER XYZ Name
In his Individual Capacity
123 Generic Street
New Castle, DE 19720
CIVIL ACTION NO:
and
OFFICER XYZ Name
In his Individual Capacity
123 Generic Street
New Castle, DE 19720
Defendants.
PLAINTIFF’S FIRST SET OF INTERROGATORIES
TO: OFFICER
Plaintiff XYZ Name by himself and on his own behalf, hereby demands that Officer XYZ Name provide the following answers to interrogatories within (30) days of service hereof and in compliance with Del. R. Civ. P. Super. Ct. 33.
INSTRUCTIONS AND DEFINITIONS
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These Interrogatories constitute a continuing request for information responsive thereto.
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Stipulated below all interrogatories shall pertain to the events of [insert date] involving Plaintiff (the “occurrence” or “incident”). The occurrence begins with XYZ Name playing craps and being threatened with being shot by another individual and concluding with XYZ Name being released by casino personnel.
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Defendants shall amend or supplement a prior response if it obtains information which causes or should cause it to know that the response, though correct when made, is no longer true and that circumstances are such that a failure to amend or supplement the response will conceal facts. Defendants shall serve each such supplemental response no later than 30 days after discovery of further information.
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Each Interrogatory should be answered upon Defendants’ entire knowledge from all sources and all information in its possession or otherwise available to it, including information from Defendants’ employees, agents, representatives, partners, or consultants and information which is known by each of them. An incomplete or evasive answer is a failure to answer.
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Each Interrogatory shall be answered separately and fully.
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Each Interrogatory shall be construed independently and not with reference to any other Interrogatory for the purpose of limitation.
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If any answer is qualified, state specifically the terms of each qualification and the reasons for it. If an Interrogatory cannot be answered in full, state the part which can be answered and answer the same in full to the extent possible; state the reason(s) why the remainder cannot be answered.
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If Defendants withhold any information called for by an Interrogatory by reason of a claim of privilege or work product, Defendants shall furnish a list setting forth as to each objection the information.
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A request to identify a document is a request to state as applicable:
a. The date of the document;
b. The type of document;
c. The names and present addresses of the person or persons who prepared the document and of the signers and addressers of the document;
d. The name of the employer or principal whom the signers, addressers, and preparers were representing;
e. The present location of the document;
f. The name and current business and home addresses of the present custodians of the original documents, and any copies of it;
g. A summary of the contents of the documents; and
h. If the original document was destroyed, the date and reason for or circumstances under which it was destroyed. -
A request to identify a person means to provide the following information to the extent known or ascertainable using reasonable efforts:
a. the person’s employer(s) and position with such employer(s) during the time period for which information is provided for the person in response to the Interrogatory;
b. the name, address and phone number of the person’s attorney, if the person is represented by an attorney with respect to this action; and
c. the last known or ascertainable address and phone number of the person, if the person is not represented by an attorney with respect to this action. -
If any Interrogatory may be answered fully by a document, the document may be attached in lieu of an answer if the document is marked to refer to the Interrogatory to which it responds.
INTERROGATORIES
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Identify if XYZ Name is employed as an officer for the New Castle Police Department.
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Identify each of the law enforcement officers present during the incident.
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Identify the employment capacity (job title and general description of duties) of each XYZ Company employee listed in interrogatory 2 above.
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Identify procedures and policies followed to arrest XYZ Name.
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Describe the actions undertaken by each law enforcement during the incident.
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State and describe with particularity each document prepared with respect to the incident.
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State and describe with particularity what each law enforcement officer stated to or said to XYZ Name during the incident.
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State and describe with particularity each response stated or said by XYZ Name to each law enforcement officer during the incident.
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State and describe with particularity each person that interacted with XYZ Name during the incident.
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State and describe with particularity the actions undertaken by law enforcement personnel to ascertain any intoxication of XYZ Name.
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State and describe with particularity the XYZ Company personnel involved during the incident.
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State and describe with particularity any actions taken by XYZ Company personnel during the incident.
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List all of the policies and procedures in effect at New Castle Police Department, including but not limited to digital, hardcopy, video, audio, training sessions governing involuntary withdrawal of blood from an individual under police custody.
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State and describe with particularity any action objected to by XYZ Name.
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Pursuant to Interrogatory 14, state and describe with particularity any alternative actions implemented.
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Pursuant to Interrogatory 15, state and describe with particularity any objection by XYZ Name to the alternative action.
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State and describe with particularity the relationship between New Castle Police Department and XYZ Company/XYZ Company.
Respectfully submitted,
/s/ XYZ Name
Dated: July 17, 2021
XYZ Name
123 Generic Street
New Castle, DE 19720
Telephone: (123) 456-7890
Plaintiff
CERTIFICATE OF SERVICE
I HEREBY CERTIFY on this 1st day of July, 2021 that a copy of Plaintiff’s Motion for Authorization to File Electronically was served via email to the Defendants at:
XYZ Name
info@xyzcompany.com
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