Sample Automobile Accident District Court Interrogatories to Defendant

BRUCE WAYNE

Plaintiff

vs.

JACK CARD

Defendant

TO: Jack Card, Defendant

BY: Bruce Wayne, Plaintiff

COMES NOW the Plaintiff, Bruce Wayne, by and through counsel, John J. Cord and Posner & Cord, LLC, and states that the following Interrogatories are addressed to you pursuant to Rule 3-421 of the Maryland Rules of Procedure. You are requested to answer each question separately and completely under oath and in writing and to serve a copy of your answers upon Posner & Cord, LLC, Counsel for the Plaintiff.

A. These Interrogatories are continuing in character so as to require you to file supplementary answers from time to time if you obtain different or additional information pertinent to the information requested by these Interrogatories.

B. Where the name or identity of a person is requested, please state that person’s full name, home address, telephone number, employer, business address and business telephone number if known to you.

C. Unless otherwise indicated, these Interrogatories refer to the time, place and circumstances of the occurrence mentioned or complained of in the pleadings.

D. Where knowledge, information or possessions of a party are requested, such request includes knowledge of that party’s agents, representatives and unless privileged, his counsel. When answer is made by a corporate defendant, state the name, address and title of the persons supplying the information, and making the affidavit, and the source of his authority to answer, as well as the source of his information.

E. The pronoun “you” refers to the party or parties to whom these Interrogatories are addressed and the persons mentioned in clause (D).

1. State your full name, address, date of birth, marital status and social security number.
2. Name the eyewitnesses to all or part of the occurrence, state their respective addresses and phone numbers, and state the location of each such eyewitness at the time of the occurrence.
3. State the names and addresses of all persons known to you who have given signed or recorded statements relative to all or any part of the occurrence and state the date the signed or recorded statement was given, including but not limited to any testimonial given at any proceedings arising out of the occurrence, to whom it was given and the present custodian of each such signed or recorded statement. Attach hereto a copy of all signed statements or a transcript of all recorded statements made by the party propounding these Interrogatories.
4. State whether you have ever been convicted of any crimes, and if so, set forth the nature of such crimes, the dates of each conviction and the name and address of the Court wherein each conviction occurred.
5. If you know of the existence of any pictures, photographs, plats, visual recordings, diagrams or objects (real evidence) relative to the occurrence or its consequences, state the nature, subject matter, date produced and obtained and the name and address of the present custodian of each, and attach hereto copies of same.
6. Give a concise statement of the facts as to how you contend that the occurrence took place, including but not limited to the names of the streets, speed of the vehicles involved, distance between the vehicles, the point of impact between the vehicles, the location of any property damage on each vehicle involved in the collision, and the total expense incurred in effecting repairs to the vehicle operated by you at the time of the collision. Attach to your answers copies of all estimates and repair records related to such repairs.
7. If you contend that the Plaintiff acted in such a manner as to cause or contribute to the occurrence, give a concise statement of the facts upon which you rely.
8. If you contend that factors other than that acts of the parties to this action caused or contributed to the occurrence, give a concise statement of the facts upon which you rely.
9. If you contend that the injuries and disability now complained of by the Plaintiff were the result of prior or subsequent injuries or illnesses, give a concise statement of the facts upon which you rely.
10. Name all experts whom you propose to call as witnesses, and for each expert, state the subject matter or the substance of the facts and opinions to which the expert is expected to testify, and a summary of the grounds for each opinion. Please attach copies of all written reports made to you by any such expert.
11. If you consumed any alcoholic beverage of any type, or any sedative, tranquilizer or other drug, medicine or pill during the 24 hours immediately preceding the incident referred to in the Complaint, state the nature, amount and type of item consumed, the amount of time over which consumed and the names and addresses of any and all persons who have any knowledge as to the consumption of those items.
12. If at the time of this accident you were the owner of the vehicle involved in the incident, state the name and address of each and every such insurer, the number of each and every policy, the name and address of each and every named operator on each policy, the name and address of each and every named excluded operator, if any, the reason for any such exclusion, and the limits of coverage under each and every policy. If you contend that you were not the owner of the vehicle operated by you at the time of the occurrence, state the name and address of the owner, whether you had the permission of the owner to operate the vehicle, the purpose for which you were operating the vehicle, the name and address of each and every insurer with whom the owner had liability insurance coverage at the time of the accident, the number of each and every policy, the name and address of each and every named operator on each policy, the name and address of each and every named excluded operator, if any, the reason for any such exclusion, and the limits of coverage under each and every such policy.
13. State what part of the vehicle in which you were situated was damaged and describe the damage. If it was estimated or repaired, state the name and address of the person who performed such estimate or repairs, the dates of such work and the cost thereof. If such vehicle is unrepaired, state the address and the hours at which it may be seen.
14. If you contend that you were injured in the accident at issue, state the full and exact names and addresses of all hospitals, clinics, physicians and other health care providers which were consulted by you with regard to the above-captioned case, and the exact number and dates of such treatments, examinations, and consultations and provide copies of any medical reports or medical records which you received or were created as a result of the occurrence, including but not limited to any PIP application completed by you in regard to this occurrence.
15. State the names, current home and business addresses, and home and business telephone numbers of all persons not heretofore mentioned in your answers having personal knowledge of facts material to this case.

Respectfully submitted,

POSNER & CORD, LLC

_______________
John J. Cord
Counsel for Plaintiff