On May 1, 2023 our client, Penny Smith was driving north on Main Street. She came to
Question:
On May 1, 2023 our client, Penny Smith was driving north on Main Street. She came to the intersection of Hail Street and Main Street, saw that the light was a green left, and proceeded to make a left-hand turn onto Hail Street. At the same time, Daniel Jones, driving south on Main Street, continued to drive straight through the red light and colliding with Smith. Smith and Jones were both injured, and police were called and summoned for ambulances. After being released from the hospital, Smith obtained the police report, only to read that the officer at the scene of the accident smelled what he claimed was alcohol on Jones' breath, and that Jones refused a breathalyzer and was arrested for driving under the influence.
Smith has hired the firm where you are employed to sue Jones for negligence. The pleadings have been served and now the firms are starting discovery. As a paralegal in the firm, you are assigned to draft interrogatories to be served upon Jones. Draft no more than 20 interrogatories and upload as a Word document.