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COURT OF COMMON PLEAS

___________________ COUNTY, OHIO

__________________________________________________
)
______________________, ) Case No. _____
Plaintiff, ) (Judge ___________________)
vs. ) PLAINTIFF'S FIRST SET
______________________, ) OF INTERROGATORIES
Defendant. ) PROPOUNDED TO
) DEFENDANT
)
__________________________________________________

Pursuant to Rule 33 of the Ohio Rules of Civil Procedure, Defendant is required to answer the
following interrogatories fully, in writing, and under oath, and to serve a copy of the Answer upon
the Plaintiff within twenty-eight (28) days from the date of receipt.

A. Where the identity of a person is requested, state full name, home address, and also business
address, if known.

B. Unless otherwise indicated, these interrogatories refer to the time, place and circumstances and
occurrences set forth in Plaintiff's Complaint.

C. Where knowledge or information in possession of a party is requested, such a request includes

knowledge of the party's agents, representatives, and employees. Where answer is made by a
corporate Defendant, state the name, address and title of the person supplying the information as
well as the source of this information.

D. The pronoun ''you'' refers to the party to whom these interrogatories are addressed and the
persons mentioned in paragraph C above.

E. You are under a duty to reasonably supplement your responses to these interrogatories, in
accordance with Rule 26(E) of the Ohio Rules of Civil Procedure.

1. State the names, addresses, telephone numbers, and positions with the Defendant of
each person who provided information for the answers of these interrogatories.

______________________

______________________

2. State the job title and job description of Plaintiff ___________________ with
Defendant on or about [date].

______________________
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______________________

3. State the name, address, and telephone number of each person known to Defendant
who witnessed in whole or in part the incident that occurred on
____________________[date], which is described in Paragraph 7-10 of the Complaint
filed herein.

______________________

______________________

4. State the name, address, and telephone number of any person known to Defendant
who submitted to Defendant any written complaint, warnings, comments, or any other
statements relating in any way whatsoever to the design, safety features or defects in
the fork lift truck referred to in paragraph 10 of the Complaint.

______________________

______________________

5. State the name, address, and telephone number of any person known to Defendant
who made verbal complaints, comments, or other statements regarding the design,
safety features, or defects in the fork lift truck referred to in paragraph 10 of the
Plaintiff's Complaint.

______________________

______________________

6. State the name, address, and telephone number of the entity which manufactured the
fork lift truck referred to in paragraph 10 of Plaintiff's Complaint.

______________________

______________________

7. State the name, address, and telephone number of the entity which designed the fork
lift truck referred to in paragraph 10 of Plaintiff's Complaint.

______________________

______________________

8. When did Defendant purchase, lease, or otherwise acquire the fork lift truck referred
to in paragraph 10 of Plaintiff's Complaint?

______________________
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______________________

9. Identify in detail each modification or alteration made to the fork lift truck referred
to in paragraph 10 of Plaintiff's Complaint following the date of acquisition.

______________________

______________________

10. State the name, address, and telephone number of any person known to Defendant
who sustained injury prior to ____________________[date], arising out of the
operation of the fork lift truck referred to in paragraph 10 of Plaintiff's Complaint.

______________________

______________________

11. Has Defendant ever had a regular maintenance schedule for the fork lift truck
referred to in paragraph 10 of Plaintiff's Complaint? If so, set forth that maintenance
schedule.

______________________

______________________

12. On ____________________[date], were there any written warnings regarding

proper operation of the fork lift truck referred to above? If so, please set forth the text
of each such written warning.

______________________

______________________

13. State the name of plaintiff's immediate supervisor on

____________________[date].

______________________

______________________

14. Did Defendant conduct an investigation or inspection of the fork lift truck
following the incident described in paragraph 7-10 of the Complaint?

______________________

______________________
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15. If the answer to the preceding interrogatory is in the affirmative, please state the
name, address, and telephone number of each individual who participated in said
investigation or inspection.

______________________

______________________

16. Does Defendant have any photographs of the fork lift truck referred to in paragraph
10 of the Complaint?

______________________

______________________

______________________

[Attorney signature]

______________________

______________________

______________________

[Firm name, address and phone number]

Attorney for Plaintiff

I hereby certify that a copy of the foregoing Interrogatories were served upon counsel for Plaintiff
and upon all other counsel of record by regular U.S. mail, postage prepaid, this _____[date] day of
____________________, 20_____[month and year].

______________________

[Attorney Name]