Plaintiff requests that defendant answer the following interrogatories.

1. State the name and address of each person who saw plaintiff’s accident as alleged in the complaint.

2. Which of said persons made written statements to defendant concerning plaintiff’s accident, and in whose custody is each such written statement.

3. State the name and address of each person having knowledge of relevant facts concerning plaintiff’s accident, as alleged in the complaint.

______________________,

Attorney for Plaintiff.

Address: _____________