SAMPLE - Standard Slip and Fall Interrogatories

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Standard Slip and Fall Interrogatories for the Court of Common Pleas in Philadelphia

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1LAW FIRM
BY: ATTORNEY NAME
IDENTIFICATION NO. XXXXX
Street Address
City, State Zip
Phone Number
Fax Number
e-mail address
_______________________________________
NAME OF PLAINTIFF

ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
PHILADELPHIA COUNTY
TRIAL DIVISION - CIVIL

Plaintiff,
v.
NAME OF DEFENDANTS

No.:

Defendants.

_______________________________________
INTERROGATORIES ADDRESSED TO DEFENDANT, NAM OF DEFENDANT
You are hereby required to answer the following Interrogatories under oath and in writing
within thirty (30) days from service hereof, pursuant to the Pennsylvania Rules of Civil
procedure, in such cases provided. These Interrogatories shall be deemed continuing, and
knowledge of the attorneys for the defendant or of the claims agents or any other agents of the
defendant shall be deemed to be knowledge of the defendant. Anything coming to your
knowledge after filing Answers, should be contained in an amended answer and served upon
plaintiff=s attorney immediately after the same is brought to your attention. Each and every and
all defendants plural if more than one Defendant has been named in the above caption.
INTERROGATORIES
1. Please state the names, telephone numbers and addresses of all witnesses and/or persons
with knowledge of the facts and events immediately preceding the accident complained
of in the Complaint heretofore filed in the above-captioned action, who are known to the
defendant, its attorneys or representatives.
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2. Please state the names, telephone numbers and address of all persons who have
knowledge of the accident complained of in the Complaint heretofore filed in the abovecaptioned action, who are known to the defendant, its attorneys or representatives.

3. Please state the names, telephone numbers and addresses of all persons who have
knowledge of the facts immediately subsequent to the accident complained of in the
Complaint heretofore filed in the above-captioned action, who are known to the
defendant, its attorneys or representatives.

4. Please state the name, telephone numbers, and addresses of all persons known or believed
to have been in sight or hearing of the accident.

5. For each and every statement in the possession of the defendant or its representative
made by the plaintiff, or by the defendant, or by any persona named in response to
questions #1 through #4 above, and for each and every statement obtained by the
defendant or anyone acting on behalf, state the names, telephone numbers and addresses
of the person or persons giving and the person or persons taking such statements, the date
or dates such statement or statements were taken, whether said statements were written or
oral, whether the statements were question and answer form, and the names, telephone
numbers and addresses of the person presently in possession of any such statements
reduced to writing.
6. For each and every oral statement referred to in Interrogatory #5 above, please detail the
contents thereof or in the alternative, affix hereto a photostatic copy of like reproduction
of any notes or transcriptions made in recollection thereof by the defendant, its attorneys
or representatives including insurance carrier.

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7. For each and every written statement referred to in Interrogatory #5, above, whether
signed or unsigned adopted or unadopted, please affix hereto a photostatic copy of like
reproduction of same.

8. For each and every person whose name was supplied in Answer to Interrogatories #1
through #5 inclusive, state whether said person:
(a) is related by blood or marriage to the defendant, and if so, how so
related;
(b) Is a friend or acquaintance of the defendant and if so, for what
duration and upon what basis;
(c) has been or will receive money or other renumeration from the
defendant for any reason whatsoever, and if so, how much, and for
what reasons:
(d) Has been or is an employee, agent and/or servant of the defendant
or anyone on the defendant=s behalf. If so, state in detail the
nature of such relationship.

9. Are you in possession of maps, plans, drawings, or photographs relating to the accident
complained of, whether they were in existence prior or subsequent to the happening
complained of, showing the locals or surrounding area of the site of the accident, the
accident, occurrence itself, or any other matter or things involved in the accident, If so,
state:
(a) The dates when such photographs, plans, maps or drawings were taken or made;

(b) The names, telephone numbers and addresses of the person or persons taking or
making the same;
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(c) Where they were taken or made;

(d) The present whereabouts of the maps, plans, drawings or photographs and the
names, telephone numbers and addresses of whosoever is in present custody or
control thereof;

(e) Affix hereto a photostatic copy or like reproduction of each and every
photographs, map, plan or drawing referred to.

10. State upon what facts defendant or defendants will rely upon to establish its defense or
comparative negligence on the part of the plaintiff.

11. State the facts upon which defendant relies in order to establish its denial of plaintiffs=
allegation that defendant was negligent.

12. Assuming the defendant to have been negligent as plaintiff alleges, do you deny that its
negligence was at least one of the proximate causes of the plaintiff=s injuries?

13. If question #12 above is answered in the affirmative, state upon what fact or facts the
defendant will rely upon to establish that defendant=s negligence, if any, was not at least
one of the proximate causes of the plaintiff=s injuries.

14. Does defendant or defendants claim that the actions of any other person, firm,
corporation or association other than that of plaintiff or defendant or defendants affect the
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rights, duties, liabilities or obligations of the parties to this action with regard to the
subject matter of this action?

15. If question #14 above is answered in the affirmative, state the names and addresses of
such person or persons, firm, corporation or association, and the facts or action of such
persons that defendant or defendants claim affect the rights, duties liabilities or
obligations of the parties to this action with regard to the subject matter of this action.

16. Is defendant or defendants protected by liability insurance for any damages which they
may be required to pay plaintiff as a result of this action?

17. If question #16 above is answered in the affirmative, state the name and address of each
such insurance company and the limits of liability of each policy and the names insured
in each said policy.

18. If defendant is a business entity, whether it is incorporated or unincorporated, state the
names, addresses and telephone number of all the individual and corporate owners.

For each and every defendant, state:
(a) Date of birth;
(b) Present home address;
(c) Present business address;
(d) Home and business address at the time of the accident, if different:
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20. Describe the weather conditions at the time of the accident and for twenty-four hours
prior thereto.

21. Describe all weather conditions prior to the time of this accident if you and your attorney
claim the same to be relevant to defendant=s defense.

22. Did you own or have any legal, equitable or other interest in the property and/or area in
question on or about the date of the accident?

23. Did any person, partnership, corporation, authority, governmental department,
government agency and/or any other entity whatsoever have any legal, equitable or other
interest in and/or to the area upon which this action is based? If so, state:
(a) The name and addresses of each;
(b) The nature, type and extent of each interest or right of each;

(c) The date when each obtained and/or became vested with such interest and/or
rights;
(d) Is there any agreement, memoranda, or any documentation whatsoever which
reflects either ownership, control, whether legal, equitable or otherwise in and/or
to the property and/or area in question on or about the date of the accident?
(e) If so, will you, without a Motion to Produce, attach copies of
documents referred to in Answer to Interrogatory #23(d).

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24. In the event the ownership and/or control and/or duty to maintain and repair is help either
in part and/or jointly, with some other person, partnership, corporation, authority,
governmental agency and/or department, and/or any other agency whatsoever, please
state for each:
(a) The name and address of each;
(b) The nature, type and extent of each interest and/or duty and/or right of each.

25. In the event that an interest, legal, equitable or otherwise is held either in full and/or part
and/or jointly, set forth in reference to identifiable stationery objects setting forth the
interest of each in the property and/or area in question on the date of the accident.

26. Does defendant believe or have any knowledge or any information tending to show that
any person and/or corporation or another entity other than the defendant, its agent,
servant, and/or employee:
(a) Was in possession or control of the property and/or area in question;
(b) Exercised or claimed the right to exercise the direction, supervision and/or control
in regards to maintenance and/or management of the property and/or area in
question during the two year period prior to the date of the accident.

25. Unless Interrogatory #26 was answered in an unqualified negative, state:
(a) The nature of the possession and/or control and the dates thereof;
(b) The names and addresses of each referred to in answer to Interrogatory #26;
(c) What are the facts and/or details that lead defendant to believe that the above
named were in possession and/or control and/or responsible for the area in
question.
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25. Did you lease, resell or transfer the property or any interest therein on or prior to the date
of the accident; if so, state:
(a) The date of such lease, sale and/or transfer;
(b) The name and address of the person, partnership, corporation, authority and/or
governmental entity or entity to whom the property was leased, sold and/or
transferred;
(c) The amount of money or other consideration received.
(d)

25. If the answer to Interrogatory #28 is that an interest in property has been leased, state:
(a)

The names and addresses of the lessors;
(b) The names and addresses of the lessees;
(c) The date each lease was executed;
(d) The amount of money or other consideration received or provided
for to be received in the lease;
(e) The date that the lease terminates or terminated;
(f) The extent of the leasehold interest;
(g) The purpose of the lease;
(h) A description of the portion and/or area leased, giving the definite
location in reference to identifiable stationery objects.

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30. Who maintains, repairs, or otherwise cares for surface of the property involved in the
suit?

31. What department of the City, if any, is responsible for the repair, maintenance and care of
the aforesaid property involved in this suit?

32. What responsibilities, if any, with respect to the maintenance and/or repair of the
aforesaid area in question have been delegated to private firms?

33. List the names and addresses of the private firms who have in any way performed any
maintenance, repair or taken part in the acre of the area in question for a period of within
two (2) years prior to the date of the accident through the present time?

34. Attach hereto records of all repairs, maintenance operations and improvements performed
on the area in question within two (2) years prior to the date of the accident up the present
time.

35. Attach hereto copies of all reports, and/or memoranda of complaints or information
registered by citizens or employees with respect to any problem or problems for the
conditions of the area in question for a period of two (2) years preceding the accident up
and until the present time.

36. What inspections and/or repairs, if any were done, on the area in question for a period of
two (2) years preceding the accident up and until the present time?

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37. As a consequence of the inspections enumerated above, was any action taken by any
person or organizations to repair and/or maintain any part of the aforesaid area in
question?

38. Did any municipal and/or governmental organization or authority send to, serve on, or
deliver to the owner and person in possession or registered agent of the property where
the accident occurred and/or anyone else, a notice of defect or to repair the said property,
location and/or area in question within two (2) years prior to the date of the accident up
and until the present time?

39. If a notice of defect and/or repair was given to the owner, and/or person, and/or entity in
possession and/or control of the property, for each such notice, state:
(a) The date of the notice;
(b) The method by which notice was given?
(c) The repairs designated to be made in the notice;
(d) Whether such repairs were made and, if so, the date and identity of same;
(e) Attach a copy of the aforesaid notice to defendant=s Answers.

31. Were repairs requested by any person, partnership, corporation, authority, governmental
agency or department or any other entity whatsoever within two (2) years prior to the
accident upon which this suit is based?
If so, for each such request, state:
(a)

The nature of the repairs or alterations which were requested;
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(b)

The date and time that the request was made;

(c)

The names and addresses of the person(s) who made the request;

(d)

The names and addresses of the person(s) to whom the request was

(e)

The reason it was made;

(f)

Whether the request was granted and, if so, the date it was granted.

made;

41. Were any instructions given by any person, partnership, corporation, authority,
governmental agency or department or any other entity whatsoever within two (2) years
prior to or at any time subsequent to the accident upon which this suit is based, that
repairs or alterations be made to the area in question?
If so, for each occasion that instructions were given, state:
(a) The nature of such instructions that were given;

(b) The date and time that they were given;

(c) The name and addresses of the person who gave the instructions;

(d) The name and address of each person to whom the instructions were given;
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(e) The reason the instructions were given;

(f) Whether a record was made of the instructions, and, if so, the name and address of
the person who has custody of each record of instructions.

42. Attach all records referred to in Answer to Interrogatory #41.

43. Were any repairs or alterations made to the area, locale, and/or location of the accident in
question for a period of five (5) years prior to and subsequent to the accident upon which
this suit is based?
If so, for each occasion that repairs were made, state:
(a) A description of the repairs or alterations made;
(b) The inclusive dates they were made;
(c) The length of time it took to make them;
(d) The exact location with reference to specific stationery objects at which they
were made;
(e) The reason they were made;
(f) At those request and at whose orders they were made;

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(g) Who was charged with the costs of the repairs or alterations;
(h) Who paid for the repairs and/or alterations.

42. For each such person who made any repairs or alterations to the said area, locale and/or
location of the accident in question, subsequent to the accident, state:
(a) His/her name and address;
(b) His/her occupation and job title;
(c) A description of the repairs and/or alterations he/she made;
(d) The inclusive dates he/she worked on the repairs and/or alterations.

42. Did anyone make a record or report of the repairs and/or alterations that were made to the
said area, locale and/or location of the accident in question subsequent to the accident?
If so, for each such record and/or report, state:
(a) The date it was made;
(b) The name and address of the person who made it;
(c) Its subject matter;
(d) The name and address of the person who has present custody and control of it;
(e) Attach a copy of all reports referred to in answering this Interrogatory to your
Answers to Interrogatories.

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42. Explain in detail your version of how this accident occurred.

43. State how often periodic inspections were made of the area, locale and/or location of the
accident in question.

44. If the inspection was undertaken by any agents, servants, workmen and/or employees of
the defendant, state names and addresses of the employees responsible for the inspection
of the area, locale and/or location of the accident tin question for a period of two (2) years
prior to the accident in question.

45. State who made the aforementioned inspection.

46. State whether or not an inspection of the area, locale and/or location of the accident in
question was made after the accident, and, if so, state:
(a) When after the accident the inspection was made;
(b) By whom the inspection was made;
(c) Whether or not any defects or conditions of disrepair were observed at the time of
the inspection;
(d) Was any report or memoranda made concerning this inspection;
(e) Attach a copy of all reports referred to in answering this Interrogatory.

42. State whether prior to the date of this accident in question if you were aware of any other
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accidents and/or injuries at the area locale and /or location where this accident occurred.
If so, state for each:
(a) the date of said accident;
(b) The names and addresses of the person or persons involved;
(c) State in detail how the accident occurred;
(d) Whether or not any actions, lawsuits or other claims were presented and, if so,
state:
(i) the names of the parties;
(ii) the court term and number;
(iii)

the identity of the attorneys and/or representatives
of the claimants.

52. For a period of two (2) years prior to the accident upon which this action is based, were
there any defects, cracks, depressions and/or dangerous conditions in the area, locale
and/or location in question?
If so, for each defect, crack or depression, state the following:
(a) The date that the defendant first had notice or such and the name and address
of the party giving notice;
(b) A description of each defect, crack and/or depression;
(c) The location with reference to specific identifiable stationery objects setting
fort the distance and direction, if known, from any such object in the area,
locale and/or location of the accident.

15

53. Did the snow and ice or other dangerous conditions referred to in the preceding
Interrogatory accumulate or increase in severity with the passage of time after it was first
noticed by the defendant?
54.

55. State how often the area in question was cleaned and/or inspected by the defendant or its
employees within one (1) year prior to the accident.

56. State when the area in question was last cleaned prior to the accident.

57. State when this accident first came to the attention of the defendant or any representative
of the defendant, by whom it was reported and to whom it was reported.

58. Set forth all facts which led defendant to deny that the defendant, its agents, servants,
workmen and/or employees owned, controlled, possessed or had under its care,
supervision or maintenance, the situs referred to in the Complaint.
59. Did a municipal authority or department thereof at any time within one (1) year prior to
the date of this accident undertake to make inspections to ascertain cracks, defects,
depressions and/or dangerous conditions in the area, locale and/or location of the accident
upon which this action is based?

59. Unless the answer to the preceding Interrogatory is in the unqualified negative, state the
following:
(a) When the municipal authority began to make inspections;
(b) What department was designated to make inspections;
(c) The frequency of the inspections;
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(d) Identify each person connected with making the inspection.

60. Identify each person from who the defendant or its attorneys or agents obtained a
statement following this accident and, if such statement is in writing, attach a copy to
your Answers to Interrogatories.

61. Has defendant, its attorneys or agents, conducted or authorized any investigation
concerning the facts, circumstances, or information relating to plaintiff(s), codefendant(s), or the situs of the accident herein involved. If so, please identify each and
every person involved in said investigation including names and addresses, job titles and
compensation arrangement or agreement. If so, attach hereto copies of all letters,
memoranda, reports and/or any other documents indicating persons contacted and/or the
result of the aforesaid investigation.
In the event the substance of and/or results of said investigation were reported
orally, please state the substance of said conversion as well as the names,
addresses and telephone numbers of persons making said report as well as names
and addresses of the person to whom said report was made.

62. State the full name and last known address, giving the street, street number, apartment
number, city, state and zip code of every witness known to defendant or to defendant=s
attorneys or anyone else acting on defendant=s behalf who claims to have seen or heard
the plaintiff make any statement or statements pertaining to any of the events or
happenings alleged in the Complaint.

63. Supply the following information with respect to each individual whose name you have
given in the answer to the preceding Interrogatory:
(a) The location or locations where the plaintiff made any such statement, or
statements;
17

(b) The name and address of the person or persons in whose presence the plaintiff
made any such statement or statements;
(c) The time and date upon which the plaintiff made any such statement or
statements;
(d) The full name and address of any other person who was present at the time
and place the plaintiff made such statement or statements;
(e) Whether defendant or anyone acting on defendant=s behalf obtained
statements in any form from any person who claims to be able to testify to the
statement or statements made by the plaintiff;
(f) The content of each statement;
(g) A photostatic or like reproduction of the statement if written, and notes or
transcription thereof if oral.

63. If the answer to Interrogatory #63(a) above is in the affirmative, then state:
(a) The names and addresses of the persons from whom any such statements were
taken;
(b) The date upon which statement were taken;
(c) The names and addresses of the employees of the person who took such
statements;
(d) The names and addresses of the persons having custody of such statements;
(e) Whether such statements were written, oral, recording device or by court
reporter or stenographer.
18

65. Was the defendant charged with any violation of law arising out of the incident referred
to in the Complaint? If so, state:
(a) The plea entered by defendant to such charge;
(b) The court in which the charge was heard;
(c) The nature of the charge;
(d) Whether or not the testimony at any trial on said charge was taken down or
recorded in any manner whatsoever.

66. If such testimony was taken down or recorded, state by whom it was recorded and
whether a transcript has been made of such recording.

67. Has defendant ever pleaded guilty to or was convicted of any crime. If so, state:
(a) The nature of the offense;
(b) The date;
(c) The county and state in which defendant was tried;
(d)
(e) The sentence defendant was given.

19

68. If defendant is an individual, has defendant ever entered or been committed to any
institution, either public or private, for the treatment or observation of mental conditions,
alcoholism, narcotic addiction or disorders of any kind? If so, state:
(a) The name and address of such institution;
(b) The length of defendant=s stay and the date of release.
69. Set forth the name and address of each and every expert, whether or not such expert will
be called for testimony at time of trial, who examined any of the persons or
instrumentalities involved with this matter or who examined any reports or documents
relating to any person or instrumentality involved in this matter.
70. For each and every expert witness named in response to Interrogatory #69 above, state in
detail the expert=s:
(a) Opinions regarding this accident or injuries therefrom;
(b) Expected testimony;
(c) Qualifications as an expert.

20

71. Affix hereto a photostatic copy or like reproduction of each and every report, analysis,
opinion or other evidence within the control of defendant or defendant attorneys or
defendant=s representatives relevant to this case produced by an expert regardless of
whether same will be used by defendant or its attorneys at trial.

72. Affix hereto a photostatic copy of like reproduction of each and every investigative report
prepared in anticipation of litigation on this matter prepared by defendant or defendant=s
attorneys or their agents or defendant=s insurance company.
73. Affix hereto a photostatic copy or like reproduction of any writing whatsoever relevant to
the subject matter of this case not previously supplied in response to a prior question,
including in particular, but without limitation to , that which has been prepared in
anticipation of litigation or trial by or for defendant or defendant=s attorneys,
consultants, sureties, indemnitors, insurers or agents, and excluding for defendant=s
attorneys only the mental, impressions, conclusions, opinions, memoranda, notes or
summaries, legal research and legal theories, excluding for all representations of the
defendant other than its attorney only the mental impressions, conclusions or opinions
respecting the value of merit of this claim or defense or respecting strategy or tactics.

LAW FIRM NAME
BY: ____________________________________
Attorney for Plaintiff(s)
Date: ___________________

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