Interrogatories - District Court (Auto-Accident)

IN THE DISTRICT COURT FOR PRINCE GEROGE’S COUNTY, MARYLAND

JANE DOE *
Plaintiff *
v. *
Case No.:
*
JOHN SMITH
*
Defendant
*

INTERROGATORIES

TO: John Smith, 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. As to the person answering these Interrogatories, state your name, present address, date of birth, your approximate height and weight at the time of the occurrence. If the Defendant is a corporation, please state the correct corporate name of the Defendant, the date of incorporation, State of incorporation, and the basis of your authority to answer Interrogatories on behalf of your Corporation.
2. State the names, addresses and telephone numbers, if available, of all persons known to the Defendant or its agents, who were eyewitnesses and/or have personal knowledge or information concerning any facts and circumstances surrounding the incident which is the subject matter of this litigation.
3. 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.
4. 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.
5. Do you expect to call any witnesses at the time of trial of this action? If so, please state the name and address and telephone number of each witness. If any witness is an expert witness, please state the subject matter that his or her testimony will relate to, the substance of the facts and opinions to 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/she has testified as an expert and for what purpose.
6. State in your own words how the incident occurred to the best of your knowledge. Include in your 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.
7. 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: (a) Identify each person who prepared, wrote or signed or participated in the preparation of the statement; (b) When the statement was prepared; (c) Why the statement was prepared; (d) Identify each person who was ever given a copy of the statement and each person presently in possession of a copy of the statement; (e) Attach copies of all such statements to your Answers to these Interrogatories.
8. To the extent not identified in your previous Answers to these 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. Pursuant to Maryland Rule 3-421(a)(3), please attach copies of all non-privileged documents.
9. Please state the name of the owner of the vehicle operated by you at the time of the occurrence that is the subject matter of this litigation, giving said owner's full name, address and telephone number.
10. If you are not the owner of the vehicle that was involved in this accident, please indicate whether you had permission from the owner to operate the vehicle, the purpose for which you were operating the vehicle, and what if any, agreements you had with the owner of the vehicle regarding your operation of the vehicle.
11. After the collision that is the subject matter of this litigation, did you observe the vehicles that were involved in the collision? If so, please state the nature of the damage that you observed as to each vehicle. If you received an estimate for the repairs for the vehicle which you were driving or which was being driven on your behalf, please attach a copy to these Answers to Interrogatories. If there is no formal estimate available, but there are repairs that have been made, please indicate the cost of any and all such repairs, and the nature of the damage repaired.
12. 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.
13. Please relate the nature and content of any statements made by you and/or the Plaintiff or other witnesses at the time of the alleged accident, which is the subject matter of this litigation.
14. Did you receive any traffic ticket, summons or were you or your employer charged by a governmental body for a violation of any law, statute, rule or regulation 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 plea was entered by you to the charge, and whether or not you paid any fine as a result of the occurrence, and if so, the date and amount thereof.
15. 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 (i.e., was the automobile you were driving covered by insurance)? 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. In addition, please furnish a copy of any and all insurance agreements referred to in your answer.

Respectfully Submitted,
FORAN & FORAN, P.A.
By: ___________________________

Ryan J. Foran
6301 Ivy Lane, Suite 600
Greenbelt, Maryland 20770-1477
301-441-2022