IN THE CIRCUIT COURT OF TENNESSEE
FOR THE THIRTIETH JUDICIAL DISTRICT AT MEMPHIS
LATOYA DOTSON and DERRICK DOTSON, SR., Individually and as legal guardians of minors, JAMES WILLIAMS and DERRICK DOTSON, JR.,
NAHTAN TAT, DOUGLAS TAT, AND JESSICA TAT
Docket No. CT-001833-14
DEFENDANTS’ FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO PLAINTIFFS
Nathan Tat, Douglass Tat, AND Jessica Tat
c/o Christopher Sobczak, (25704)
Attorney for Defendant, Nathan Tat
4515 Poplar Avenue, Suite 329
Memphis, TN 38117
Defendant submits the following Interrogatories pursuant to the Tennessee Rules of Civil Procedure, to be answered fully and in writing, and under oath, within the time prescribed by law.
Defendant also submits the following Requests for Production of Documents pursuant to the Tennessee Rules of Civil Procedure. INTERROGATORIES
1. State your full name, date and place of birth, your Social Security Number, the street address of your current residence and the length of time you have resided there. ANSWER: LaToya Melton Dotson
Clarksdale, MS – 09/12/1978
1638 Beaver Trail Drive
Cordova, TN 38016- 10years
If you are now or have ever been married, as to each marriage, state the name of your spouse, the date and place of the marriage, the date the marriage was terminated, if terminated by divorce, the date and place of the divorce, the name and the location of the Court, and the present or last known address of any divorced spouse.
ANSWER: Derrick Dotson
August 12, 2006
Describe your educational or vocational background, including names and addresses of every school, college, university, or vocational school attended, dates of attendance, and degree obtained, if any.
ANSWER: Rust College – 1998-2000
Mississippi Valley State University- 2002-2003
State the name and address of each physician or other practitioner of the healing arts who has treated you for the injuries or medical conditions upon which this action is based, and attach copies of any and all medical records in the possession of you or your attorney pertaining to this treatment.
ANSWER: Dr. Elizabeth Mann
State the name and address of each physician or other practitioner of the healing arts not named in response to Interrogatory Number 4 who has examined you or who has consulted regarding any other injuries or medical conditions within the ten (10) years preceding filing of your Complaint, and briefly describe the injury or condition, the approximate date each physician was consulted, and the treatment received. Attach copies of any medical records in the possession of you or your attorney with respect to any such treatments or consultations. ANSWER:
State the name and address of each hospital or clinic in which you have received treatment, consultation, examination or advice for the injuries or medical conditions mentioned in the Complaint or for any injuries you received or diseases or medical conditions from which you suffered at any time within the ten (10) years preceding filing of the Complaint. Attach copies of any medical records in the possession of you or your attorney with respect to any such treatments or consultations.
ANSWER: Methodist Le Bonheur Germantown Hospital
7691 Poplar Ave.
Germantown, TN 38138
Itemize and attach copies of all bills or other relevant documents reflecting the cost and expense of all medical treatment and services rendered and medicine received as a result of the injuries or medical conditions described in the Complaint. As to each item, list the person or firm with whom such expense was paid or incurred, the date or period on or during which it was...
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