Best employment interrogatory questions

Economic damages in employment termination cases

Getting information on the jobs that the individual worked at and applied for after the defendant terminated them; helps the labor economist work up the damages and determine what types of jobs may have been available to the plaintiff. In addition, the information is used to assess the plaintiffs attempts to pursue available job opportunities i.e. mitigate their damages.

Here are some questions that are helpful in getting that information

INTERROGATORY NO.1

Identify each employer for whom you worked with since last employed by the defendant

INTERROGATORY NO.2

If you are no longer employer by an employer identified in response to interrogatory no.1, state when the employment ended and why

INTERROGATORY No.3

State the job duties, wages and responsibilities that you had at each employer identified in Interrogatory No.1

INTERROGATORY No. 4

Describe and state how much earned from any self-employment since leaving the defendant

INTERROGATORY No.5

Identify anyone with whom you have sought employment since you were last employed by the defendant

INTERROGATORY No.6

State whether you rejected or declined in accepting any offer of employment since last employed with the defendant.

Once the information is received, we should check (at deposition or by interview):

* If the list of jobs that the plaintiff provided includes all the jobs or is it just a representative job list? This is important because now the list can be used to determine how many jobs the person applied for and if the number of jobs searched for are consistent with the number of jobs a typical person will apply for when they are looking for a job)

* For any jobs that were turned down make sure that the plaintiff has listed that reason and the wage that would have been received by the person

* List and make sure that no other jobs have been received since the interrogatory answers

* Get the plaintiff to list out all programs, training, and capabilities that they possess. For example, if the plaintiff is a computer support person, get the full list of Microsoft certifications, list of software that the person can support (for example the windows products line), details on the networking capabilities they have (for example can they set networks up (if so, what type LINUX, Novell, etc.) or do they focus on making sure the computers talk to the network) also make sure that questions are ask to see what level or types of classes the person is currently pursuing.