Interrogatories - Circuit Court Auto Accident

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

JOHN SMITH *
*
Plaintiff *
v. * CAL00-000
JOE SMITH *
Defendant *

INTERROGATORIES

TO: Joe Smith, Defendant
FROM: John Smith, Plaintiff
c/o Ryan J. Foran, Esquire

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. As to the person answering these Interrogatories, state your name, present address, date of birth, Social Security number, your approximate height and weight at the time of the occurrence.
2. State the names, address and telephone numbers, if available, of all persons known to the defendant or its agents, who have personal knowledge or information concerning any facts and circumstances surrounding the incident which is the subject matter of this litigation.
3. State the names, addresses and present telephone numbers if available of all eyewitnesses to all or part of the occurrence which is the subject matter of this litigation.
4. If you contend that the Plaintiff acted in such a manner as to cause or contribute to the occurrence that is the subject matter of this litigation, please give a concise statement of any and all facts upon which you rely.
5. If you contend that a person not a party to this action acted in such a manner as to cause or contribute to the occurrence that is the subject matter of this litigation, please give a concise statement of the facts upon which you rely.
6. Please state the names and addresses of all persons who investigated the cause or circumstances of the occurrence that is the subject matter of this litigation for you.
7. Do you expect to call any expert witnesses at the time of trial of this action? If so, please state the name and address and telephone number of each expert witness, the subject matter that his or her testimony will relate to, the substance of the facts and opinions of which he or she is expected to testify, a summary of grounds of each such opinion rendered to you. Please attach a copy of the curriculum vitae of the expert, which should include educational background and degrees held by such witness, and other specific cases in which he has testified as an expert and for what purpose.
8. Have you ever been arrested, convicted or adjudicated for the alleged commission of a traffic violation in the jurisdiction in which this accident occurred? If so, please state the time, date and location of each such arrest, detention, conviction or adjudication, the specific charges for which there was an arrest, detention, conviction or adjudication, and the disposition of each such charge.
9. State in your own words how the incident occurred to the best of your knowledge. Include in our answer but do not limit it to: (a) your observations of the physical movements of each person or object involved; (b) what each person said, and to whom each statement was made (if you do not recall exact wording, state the contents of such statement); (c) the exact wording or content of all statements made by yourself, and identify the person to whom said statements were made; (d) your physical movements; (e) the time each of the above actions and/or statement occurred; and (f) what evasive maneuvers were utilized by any of the participants to avoid the collision that is the subject matter of this litigation.
10. Have you, or any other person to your knowledge, prepared, written, signed or otherwise participated in the preparation of a written statement describing the circumstances of these events? If so, for each statement, state the following:
    1. Identify each person who prepared, wrote or signed or participated in the preparation of the statement.
    2. When the statement was prepared.
    3. Why the statement was prepared.
    4. Identify each person who was ever given a copy of the statement and each person presently in possession of a copy of the statement.
    5. Attach copies of all such statements to your answers to these Interrogatories.
11. Do you presently possess or have access to copies of any written statements or recordings, mechanical, electrical, stenographical, typed transcripts or others, of any statements made by any person regarding any part of this claim which concerns the subject matter of the alleged occurrence? If so, please attach a copy of said statements to these Answers to Interrogatories.
12. To the extent not identified in your previous answers to Interrogatories, please identify with particularity, every document, photograph, plat, diagram, tape or other tangible object in your possession, or the possession of your attorneys or agents, or if not in your possession, which you know to exist or have existed and in any way pertains to the allegations of the declaration or complaint of the alleged occurrence, that is the subject matter of this litigation. Identify each document or object by a brief description, date, title, and author or preparer, if applicable, and state who presently has custody of same, and attach copies of any such photographs, plats or diagrams or any other document provided in answer to this question to your answers to these Interrogatories.
13. At the site of the occurrence that is the subject matter of this litigation and within the 500 yards immediately preceding the site of the occurrence, please indicate what the road conditions were, including whether there were any abnormal bumps, holes or the like, any traffic control devices, signs, emergency vehicles, authorized traffic control individuals, abnormal weather conditions existing at the time of the accident. Your answer to these questions should include a brief description of any applicable bumps, potholes, traffic signs, lights or weather difficulty at the time of the occurrence.
14. As to the occurrence that is the subject matter of this litigation, please state the following:
    1. The speed of the vehicle you were in, 300 feet, 200 feet, 100 feet from, and then at the point of impact.
    2. From a point approximately two blocks prior to the point of impact state, the lane of traffic you were in, whether or not you ever changed lanes before the point of impact, and detail the mechanical operations and maneuvers of the driver of the vehicle you were in from this point up to the point of impact.
    3. The time and place you last entered the vehicle you were in just prior to the accident, your destination, and the route you took from the point of origin up to the point of impact.
15. Please identify the name of the operator and owner of the vehicle you were in at the time of the occurrence that is the subject matter of this litigation, giving said operator’s and owner’s full name, legal address and telephone number.
16. Please identify the relationship between you and all other persons who were in the vehicle at the time of the collision herein. In your answer please indicate if you were related in any way to the driver of the vehicle, how long you have known the driver of the vehicle, how you happen to know the driver of the vehicle, whether you attended the same school and grade in school as the driver of the vehicle, whether you socialized with the driver of the vehicle, whether you knew the parents of the driver of the vehicle, whether you had ever been to a birthday party for the driver of the vehicle, whether you knew the age of the driver of the vehicle.
17. Did you consume any drugs, medicines, or alcoholic beverages within twenty-four hours prior to the occurrence that is the subject matter of this litigation? Include in your answer the place where such drugs were consumed, who was with you at the time you consumed drugs, medicines or alcoholic beverages, what you consumed in the way of drugs, medicines or alcoholic beverages, how drugs, medicines or alcoholic beverages were obtained, nature of the drugs, medicines or alcoholic beverages, and the amount thereof.
18. After the collision that is the subject matter of this litigation, did you observe the vehicles that were involved in the collision? If so, would you please state the nature of the damage that you observed as to each vehicle.
19. Please state the itinerary of your vehicle on the date of the occurrence that is the subject matter of this litigation, including the time and place of the beginning of the trip, the time and duration of each stop, the place of destination, and the expected time at the place of each stop, and final destination.
20. Please relate the nature and content of any statements made by you or any other occupants of the vehicle at the time of, immediately before or after the occurrence herein?
21. Did you receive any traffic ticket, summons, juvenile citation with respect to the occurrence. If so, state the nature of the charges, the time, date and place of any hearing as a result thereof, the verdict rendered at any hearing, what pleas was entered by you to the charge, and whether or not you paid any fine as a result of the occurrence, and whether or not you paid any fine as a result of the occurrence, and if so, the date and amount thereof.
22. Are there any insurance agreements, including but not limited to, liability, 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 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. If you will do so without a request for production of documents, please furnish a copy of any and all insurance agreements referred to in your answer.
23. Do you contend that the accident in this case was due to any type of mechanical or brake failure of the vehicle you were operating at the time of the accident or was unavoidable for any reason, including but not limited to any sudden emergency? If you make.

Respectfully submitted,
FORAN & FORAN, P.A.

Ryan J. Foran F00626
Attorney for the Plaintiff
6301 Ivy Lane, Suite 600
Greenbelt, MD 20770
(301) 441-2022