SECOND SET OF INTERROGATORIES


TO: GEICO, Defendant

FROM: Plaintiff


The following Interrogatories are propounded pursuant to the Maryland Rules of Procedure and are to be answered fully and under oath:

a. These Interrogatories are continuing in character, so as to require you to file supplementary answers if you obtain further or different information before trial.

b. Where the name or identity of a person is requested, please state full name, home address, and also business address, if known, as well as the home and business telephone number.

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 or information in possession of a party is requested, such request includes knowledge of the party's agents, representatives, and, unless privileged, his attorneys. When answer is made by a corporation or other legal entity, state the name, address, and title of the person supplying the information, and making the affidavit, and the source of his information.

e. Said Interrogatories shall include the following definitions:

i. Any request to identify any record, documents, or writing shall include identification as to: (a) the date the same was dated or otherwise prepared; (b) the name, address, and title of the person preparing same; (c) the name, address, and title of the person for and to whom the same was prepared and addressed; (d) the name, address, and title of all persons to whom copies of the same were furnished or otherwise forwarded; (e) the title and other identifying designation given the same; (f) the subject matter and content of the same; and (g) the name, address, and location and title of the person having possession.

ii. The pronoun "you" refers to the party to whom these Interrogatories are addressed, its agents, servants, employees, representatives, officers, or anyone acting for or on behalf of that party.


INTERROGATORIES


1. Your response to request for admissions indicates that you believe that Plaintiff was not injured in any way in this car crash. See Plaintiff's First Set of Request for Admissions, Question and Answer #15, which states "Plaintiff was injured as a result of the car crash." Set forth the reasonable inquiry that you made before denying Request for Admission #15 and set forth all facts upon which you intend to rely upon at trial to support your denial. If the due diligence inquiry that you conducted in answering this request for admission was different from the one you conducted as an insurance company investigating the claim that your insured made under your insurance contract with her, set forth the nature and scope of that inquiry.

2. You have indicated that the treatment given and the bill for services rendered to Plaintiff at Union Memorial Hospital, the Injury Treatment Center of Maryland, Dr. Cyrus Pezeshki, Dr. Kyu C. Lee, Albert Folgueras, Joseph A. Ciotola, Jr., Baltimore Imaging Center, and National Medical Imaging were fair, reasonable, necessary, and causally related to the car crash complained of in the Plaintiff's Complaint. See Plaintiff First Set of Request for Admissions, Question and Answer, #21- #28. (Note: GEICO did not answer Request #28 but Plaintiff assumes this was a typographical error and GEICO intended to deny this request.) Set forth the reasonable inquiry that you made before denying these requests and set forth all facts upon which you intend to rely upon at trial to support your denial. If the due diligence inquiry that you conducted in answering these requests for admission was different from the one you conducted as an insurance company investigating the claim that your insured made under your insurance contract with her, set forth the nature and scope of that inquiry.

3. Does GEICO believe that it owes Plaintiff any money under GEICO's insurance contract with her?  

4. Does GEICO believe that Plaintiff has been dishonest with them regarding the car crash and the injuries she suffered? If so, state with specificity what facts she gave you that you believe were dishonest? Set forth in your answer who made the determination that she was dishonest in the information she relayed to you.

5. Does the Defendant know of any person believed or understood by Defendant to have personal knowledge of the allegations as set forth in the Complaint on the damages claimed by Plaintiff?
Respectfully submitted,

MILLER & ZOIS, LLC.


Ronald V. Miller, Jr.
Laura G. Zois
Empire Towers, Suite 615
7310 Ritchie Highway
Glen Burnie, Maryland 21061
(410)553-6000
(410)760-8922 (Fax)
Attorneys for the Plaintiff


Certificate of Service

I hereby certify that the foregoing Second Set of Interrogatories was sent via U.S. Mail, first-class, postage prepaid, this 21st day of July, 2004, to:

Curtis T. Monroe
3 Braided Whip Court
Woodlawn, Maryland 21207

Gregory S. Fanshaw, Esq.
Besok & Mullen
231 E. Baltimore Street, Suite 901
Baltimore, Maryland 21202-3447
Attorney for Defendant GEICO