IN THE CIRCUIT COURT OF TENNESSEE
INTENDED FOR THE THIRTIETH JUDICIAL AREA AT MEMPHIS
LATOYA DOTSON and DERRICK DOTSON, SR., Individually as legal guardians of those under 18, JAMES WILLIAMS and DERRICK DOTSON, JUNIOR.,
NAHTAN TAT, DOUGLAS TAT, AND JESSICA TAT
Docket No . CT-001833-14
DEFENDANTS' FIRST SET OF INTERROGATORIES AND REQUESTS INTENDED FOR PRODUCTION OF DOCUMENTS TO PLAINTIFFS
Nathan Tat, Douglass Tat, AND Jessica Tat
c/o Christopher Sobczak, (25704)
Attorney for Accused, Nathan Tat
4515 Poplar Avenue, Package 329
Memphis, TN 38117
Defendant submits the following Interrogatories pursuant towards the Tennessee Rules of Detrimental Procedure, being answered completely and in producing, and underneath oath, inside the time recommended by law.
Defendant also submits the following Needs for Development of Files pursuant towards the Tennessee Guidelines of City Procedure. INTERROGATORIES
1 . State your full name, date make of delivery, your Ssn, the street addresses of your current residence as well as the length of time you could have resided right now there. ANSWER: LaToya Melton Dotson
Clarksdale, MS – 09/12/1978
1638 Pussy Trail Drive
Cordova, TN 38016- 10years
2 . If you are now or have have you ever been married, concerning each marital life, state the name of your spouse, the date and place of the marriage, the time the marriage was terminated, in the event that terminated by divorce, the date and place of the divorce, the brand and the location of the Court, and the present or perhaps last well-known address of any divorced spouse.
SOLUTION: Derrick Dotson
August doze, 2006
three or more. Describe your educational or vocational background, including names and addresses of every institution, college, school, or business school went to, dates of attendance, and degree obtained, if any kind of.
ANSWER: Rust College – 1998-2000
Mississippi Valley Express University- 2002-2003
some. State the name and address of every physician or other medical specialist of the healing arts who have treated you for the injuries or medical conditions upon which this action relies, and connect copies of any and all medical records inside the possession of you or your attorney associated with this treatment.
ANSWER: Doctor Elizabeth Mann
5. Express the term and addresses of each medical doctor or other practitioner from the healing disciplines not known as in response to Interrogatory Quantity 4 who has examined you or that has consulted concerning any other traumas or medical conditions within the 10 (10) years preceding filing of your Issue, and in brief describe the injury or condition, the approximate time each medical doctor was contacted, and the treatment received. Affix copies of any medical records inside the possession of you or your attorney with respect to any such treatment options or consultation services. ANSWER:
6. Condition the brand and talk about of each medical center or center in which you have obtained treatment, assessment, examination or advice for the accidental injuries or medical conditions mentioned inside the Complaint or perhaps for any traumas you received or disorders or medical conditions from which you suffered at any time within the five (10) years preceding processing of the Issue. Attach clones of virtually any medical data in the possession of you or your lawyer with respect to any such treatments or perhaps consultations.
SOLUTION: Methodist Votre Bonheur Germantown Hospital
7691 Poplar Ave.
Germantown, TN 38138
several. Itemize and attach replications of all charges or various other relevant paperwork reflecting the cost and expenditure of all medical therapy and services rendered and medicine received as a result of the injuries or medical conditions described in the Issue. As to each item, list the person or firm with whom this sort of expense was paid or perhaps incurred, the date or perhaps period on or when it was...