Working on interrogatories . Should i just send a first set asking the hotel to identify the bouncers and then when I receive those answers send togs to the identified bouncers on the specifics of the event ? I assume I cannot ask the DOE bouncers to answer questions yet , right ?
I would strongly encourage you to hire a lawyer who handles cases involving inadequate security. While people have the right to handle cases pro se (on their own), it is not always the best thing to do, and most Courts require non-lawyers acting on their own behalf to follow the same rules of procedure and evidence as lawyers. Assuming you are asking about John Doe Defendants, you need to identify them, and join them in the suit individually before you can serve discovery on them. Good luck.
You would likely be best served by having the bar/hotel identify any and all individuals involved with (or even working on) the night of the incident. You could then, by way of a DOE amendment, DOE in the individuals responsible. It may be difficult to get an accurate response from the bar/hotel at this point if you are merely referring to the actions of unnamed DOE defendants. Also, the questions about whether the bouncers engaged in an argument with the plaintiff or struck the plaintiff are likely best saved for after you have precisely identified the bouncers, and DOE'ed them into your case; you could then use those questions as part of your requests for admission to both the bouncers and the bar/hotel.
Trying to resolve a personal injury case without a lawyer is silly, as you will most likely sabotage your good claim. Is that a good idea really? You would need to retain a personal injury lawyer to investigate. Find a lawyer with a low contingency fee, less than 30%, so you get the lion’s share of the settlement, not your lawyer. Thus, don’t get hurt twice by paying a huge fee. Good luck.
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