Form 212. Defendant’s Interrogatories—Loss of Consortium

Defendant’s Interrogatories—Loss of Consortium 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 Plaintiff, , under oath, within sixty (60) days of the filing hereof in compliance with Practice Book Section 13-2. Definition: ‘‘You’’ shall mean the 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 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) Please state your name, address and occupation. (2) Please state the date and place of your marriage. (3) Do you have any children? If so, state their names and dates of birth. (4) Describe the nature of your loss of consortium claim. (5) During your marriage, please list your employers, the length of time employed by each, and the average number of hours worked per month. (6) Prior to the incident which is the subject of this lawsuit (‘‘the incident’’), did your spouse regularly perform work, services and/or chores (‘‘services’’) in or around the home? (7) If the answer to the previous interrogatory is in the affirmative, please describe the nature and frequency of such services. (8) Subsequent to the incident, did such services change? If so, state how, and describe the impact of this change on you. (9) Subsequent to the incident, did anyone other than your spouse perform the services usually performed by your spouse in and around the home? (10) If the answer to the previous interrogatory is in the affirmative, please state the name(s) and address(es) of each person(s), the amount paid, the period of time they were hired and what services they performed. (11) Have you or your spouse ever instituted legal proceedings seeking a divorce or separation? If so, state when.