Discovery - Circuit Court (Slip And Fall)

IN THE CIRCUIT COURT FOR PRINCE GEORGE’S COUNTY, MARYLAND

JANE DOE *
Plaintiff * v. * Case No.:
SAFESTORE *
Defendant *

INTERROGATORIES

TO: SAFESTORE, Defendant
FROM: JANE DOE
c/o Ryan J. Foran, Attorney for Plaintiff

You are requested to answer the following Interrogatories:

1. These Interrogatories are continuing in character so as to require you to file supplementary answers if you obtain further or different information before trial.
2. Where name and identity of a person is required, please state full name, home address and also business address, if known.
3. Unless otherwise stated, these Interrogatories refer to the time, place and circumstances of the occurrence mentioned and complained of in the declaration or complaint.
4. Where knowledge or information in possession of a party is requested, such request includes knowledge of the party's agents, representatives, and unless privileged, his attorney's. When answer is made by corporate defendant, state the name, address and title of persons supplying the information and making the affidavit, and announce the source of his or her information.
5. The pronoun "you" refers to the party to whom these Interrogatories are addressed and the parties mentioned in clause (d).

1. State the name, address of the person answering these interrogatories for defendant and the position said person holds with defendant. If the Defendant is a corporation, state the correct corporate name of the defendant, state of incorporation, date of incorporation and the basis of your authority to answer these interrogatories on behalf of the defendant.
2. Please describe in detail how the alleged occurrence happened after you have made a diligent inquiry of all of the defendant's agents or employees who have any knowledge of the occurrence.
3. Did any agent or employee of the defendant witness the occurrence which resulted in the injury to the plaintiff? If so, please give that person's name and address.
4. Please describe in complete detail everything you or any agent or employee of the defendant observed about the plaintiff, including the appearance of any injuries, immediately before, during or after the plaintiff's alleged occurrence.
5. Please state what you or any agent or employee of the defendant saw or heard immediately after the alleged occurrence that is the subject matter of these proceedings.
6. Please state whether you or any agent or employee of the defendant rendered any assistance of any kind to the plaintiff immediately after the alleged occurrence. If so, state that person's name and address and what assistance was rendered.
7. Please state in complete detail the substance of any communication, including, words and gestures, that you or any agent or employee of the defendant conveyed to the plaintiff or was conveyed by plaintiff, at or after the time of the alleged occurrence.
8. Please state what precautions, if any, were taken by you, or any agent or employee of the defendant prior to the alleged occurrence, to prevent injuries to persons in the position of the plaintiff.
9. With regard to the slippery substance at the place of the occurrence describe such slippery substance fully and completely, including in your answer the size of the area covered with the slippery substance.
10. Do you contend that a defect or defective condition in any way caused or contributed to the alleged occurrence? If so, who do you contend was responsible for the alleged defective condition, describe the condition fully and how it caused the alleged occurrence.
11. Were repairs of any kind made to the immediate area of the alleged occurrence within one year prior to this occurrence?
12. If your answer to the preceding interrogatory is in the affirmative, please state:
    1. what such repairs consisted of;
    2. the name and address of the person, firm or corporation which made such repairs;
    3. the date and time of day when such repairs were made.
13. Was the defendant in exclusive possession of the premises at the site of the occurrence at the time and place where the alleged occurrence happened? If not, please name those individuals who were also in possession of the premises.
14. Was this defendant the owner of the premises at the site of the occurrence? If not, please give the full name of the owner.
15. Did you or any agent or employee of the defendant have any knowledge of the existence of the slippery substance at the location of the alleged occurrence?
16. If you have answered the preceding interrogatory in the affirmative, please state:
    1. how you or any agent or employee of the defendant acquired such knowledge;
    2. how long you or any agent or employee of the defendant knew the alleged condition had existed prior to the alleged occurrence.
17. Please describe in detail any warning or signal, either written or oral, sign or device or otherwise, given by the defendant to the plaintiff prior to the alleged occurrence.
18. Did you or any agent or employee of the defendant make any examination or inspection of the place or area where the plaintiff alleges that the occurrence happened at any time prior to or subsequent to the alleged occurrence?
19. If your answer to the preceding interrogatory is in the affirmative, please give the following information with regard to any examination or inspection which was made or such place or area prior to or subsequent to the happening of the occurrence:
    1. the date and time of day of such examination or inspection;
    2. the identification, including the name and address of the persons making such examination or inspection;
    3. in complete detail, what such examination or inspection consisted of;
    4. in complete detail, what such examination or inspection revealed or disclosed.
20. Did you or any agent, employee or other representative of the defendant ever take or receive any statement, either oral or in writing, from any person, including parties, who ah any information or knowledge relating to the alleged occurrence?
21. If your answer to the preceding interrogatory is in the affirmative, please state as to each such person:
    1. his/her identification; name and address;
    2. the date of any such statement;
    3. the substance, as best you can give it, of any such statement;
    4. if such statement was in writing, either attach a copy or indicate where and when such statement may be examined by counsel.
22. Do you expect to call any expert witnesses at the trial of this action? If so, state the following:
    1. the name and address of each expert witness;
    2. for each such witness state (1) the subject matter of his/her testimony, (2) the substance of the facts and opinions to which he is expected to testify, (3) a summary of the grounds of each such opinion, (4) the educational background and degrees held by such witness, (5) such witnesses' membership in any professional societies or organizations. and the identification number,(6) any courts in which the witness is qualified as an expert, and the name of such court and the caption of said action, (7) whether the witness was ever suspended from engaging in his/her profession, and if so, when did this occur and which jurisdiction, state, county or city took such action.
23. Do you contend that the plaintiff assumed the risk or was contributorily negligent regarding the alleged occurrence? If so, please state each and every fact upon which you rely for that contention.
24. Do you contend that someone not a party to this action is in any way responsible for the alleged occurrence or injuries resulting therefrom? If so, please state the name and address of said person and why you so contend.
25. Please state the name and address of each person who has personal knowledge about any facts relevant to this matter.
26. Are there any insurance agreements, including but not limited to, umbrella/all risk policies under which any person carrying on an insurance business might be liable to satisfy part or all of a judgment that might be entered in this action or to indemnify or reimburse for payments made to satisfy the judgment? If so, please state the names of the insurance companies, the policy numbers and the insurance policy liability limits which are subject to this action.
27. Please describe the lighting, direct and indirect, that was in operation in the immediate vicinity of where the alleged occurrence took place.

Respectfully submitted,
FORAN & FORAN, P.A.

Ryan J. Foran
6301 Ivy Lane, Ste. 600
Greenbelt, Maryland 20770-1477
(301) 441-2022
Attorney for Plaintiff