Civil Law & Litigation for Paralegals 1st Edition by Neal Bevans

تمرين 30

Draft interrogatories. Our client, Joe Doe and his wife Flo were driving through their hometown on their way to go out to dinner. The restaurant was on the other side of the railroad tracks that run through the town. As they approached the intersection of the track with the road, Joe Doe thinks he looked both ways and didn't see anything but isn't sure because of his injuries.
It is undisputed that just as the car Doe was driving began to cross the tracks, it was struck by a southbound train, owned and operated by Columbo Railway. The force of the impact impaled Doe's car on the front of the engine, and the car was dragged 242 feet down the track before the car fell off to the side.
Flo Doe was killed at the scene, and Joe Doe was severely injured, requiring hospitalization for four months before he was released, in a wheelchair, never to walk again. Joe came to our firm, wanting to sue, because the trees that grow next to the track block anyone's view and everybody in town knows it.
We have filed a Wrongful Death action on behalf of Flo and a separate action for damages for Joe's injuries. We are now at the stage where interrogatories are to be filed. Draft 10 questions for the railroad company.