Form 210. Defendant’s Interrogatories—

Defendant’s Interrogatories— Workers’ Compensation Benefits—Intervening Plaintiff No. CV- : SUPERIOR COURT (Plaintiff) : JUDICIAL DISTRICT OF VS. : AT (Defendant) : (Date) The undersigned, on behalf of the Defendant, hereby propounds the following interrogatories to be answered by the Intervening Plaintiff, , under oath, within sixty (60) days of the filing hereof insofar as the disclosure sought will be of assistance in the defense of this action and can be provided by the Intervening Plaintiff with substantially greater facility than could otherwise be obtained. Definition: ‘‘You’’ shall mean the Intervening Plaintiff to whom these interrogatories are directed except that if suit has been instituted by the representative of the estate of a decedent, ward, or incapable person, ‘‘you’’ shall also refer to the Intervening Plaintiff’s decedent, ward or incapable person unless the context of an interrogatory clearly indicates otherwise. In answering these interrogatories, the Plaintiff(s) is (are) required to provide all information within their knowledge, possession or power. If an interrogatory has subparts, answer each subpart separately and in full, and do not limit the answer to the interrogatory as a whole. If any interrogatories cannot be answered in full, answer to the extent possible. (1) State the name, business address, business telephone number, business email address and relationship to the workers’ compensation lien holder of the person answering these interrogatories. (2) State the workers’ compensation claim number and the date of injury of each workers’ compensation claim that gave rise to the lien asserted by the workers’ compensation lien holder. (3) State the total amount paid on each claim referenced in the answer to Interrogatory #2, specifying the amount of medical benefits, loss of income benefits, and specific award benefits paid. (4) Identify any First Report of Injury, Notice of Claim for Compensation, Notice of Intention to Reduce or Discontinue Benefits, Notice to Administrative Law Judge and Employee of Intention to Contest Employee’s Right to Compensation Benefits, and any reports of medical exams requested by the administrative law judge, respondents and/or employer arising out of the incident/occurrence alleged in the Complaint. (5) Identify any voluntary agreements, approved stipulations to date, approved full and final stipulations and findings and awards, and findings and denials. (6) Identify the claims referenced in your answer to Interrogatory #2 that are still open. COMMENT: These standard interrogatories are intended to tailor the discovery from the intervening compensation carrier to the limited role and limited material information in the workers’ compensation lien holder’s file. The existing standard interrogatories directed to the Plaintiffs place an unnecessary burden on the parties, result in discovery disputes, and require the compensation carrier to produce information and documentation, in many instances, that is duplicative of the responses engendered by the same interrogatories served upon the Plaintiff in the case. DEFENDANT, BY