IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND

WILLIAM BELICHICK- Plaintiff

v

WILLIAM PARCELLS- Defendant

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         CASE NO. 24-C-02-00380
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PLAINTIFF’S INTERROGATORIES TO DEFENDANT


TO: Defendant Employer
FROM: Plaintiff

      Plaintiff, William Belichick, by and through his attorneys, Ronald V. Miller, Jr., Laura G. Zois, and Miller and Zois, LLC, requests that the Defendant, William Parcells, answer the following Interrogatories fully, under oath, and in accordance with the Maryland Rule of Civil Procedure, Rule 2-421, subject to the instructions set forth below:


INSTRUCTIONS

  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. Unless otherwise stated, these Interrogatories refer to the time, place, and circumstances of the occurrence mentioned or complained of in the Complaint.
  3. Where name and identity of a person is required, please state full name, home address and also business address, if known.
  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 the Interrogatories are addressed and the parties mentioned in clause (d).
  6. "Identify" when referring to an individual, corporation, or other entity shall mean to set forth the name and telephone number, and if a corporation or other entity, its principle place of business, or if an individual, the present or last known home address, his or her job title or titles, by whom employed and address of the place of employment.

    INTERROGATORIES
  7. State your full name, current address, date of birth, social security number and work address or if you are the representative of a company answering these Interrogatories state your title, your affiliation with the Defendant, and the length of time you have been employed by the Defendant, and list all the positions you held in the past and your current position.
  8. Identify any individual that you are aware that has personal knowledge of the facts and circumstances of this case, including eyewitnesses and any individuals who arrived on the scene within two hours after the occurrence.
  9. If anyone investigated this matter for you, including medical experts, private investigators or insurance adjusters and state their name(s) and address(es), and state whether such investigation was reduced to writing. If said investigator obtained any signed statements or recorded statements, identify the person who gave the statement and attach to your Answers a copy of any said statement.
  10. If you know of the existence of any pictures, photographs, plats, visual recorded images, diagrams or objects relative to the occurrence, the Plaintiff’s physical condition, or the scene of the occurrence, identify the substance of such recording and the present custodian of each such item.
  11. Please identify the owner and the driver of the vehicle involved in the accident with the Plaintiff and under what specific circumstances the driver of the vehicle was permitted to operate the owner’s vehicle on the date of the accident.
  12. Please state the relationship of the driver to the owner of the vehicle which was involved in the accident with the Plaintiff.
  13. Please state where Defendant William Parcells was heading to and the time of the accident
    and where Defendant William Parcells was coming from and their expected time of arrival.
  14. Please list all accidents involving Defendant William Parcells, within the past five (5) years. For each such accident, please include the name and address of any driver of 's vehicle involved, the name and address of any other driver involved, the court and case number of any action that resulted, and the result of each such action.
  15. Please state the extent of Defendant Baltimore Masonry’s knowledge of Defendant William Parcells’ driving history.
  16. Please list all insurance agreements you have regarding the vehicle operated by Defendant William Parcells at the of the collision with the Plaintiff, including the name of the insurance company, the name of the policy owner, the policy number, the type of coverage, the amount of coverage (specifying its upper and lower limits) and the effective dates of said policy for the past five (5) years.
  17. State whether Defendant William Parcells was acting as the agent, servant or employee of Defendant Baltimore Masonry at the time of the occurrence.
  18. Identify the property damage done to each vehicle as a result of the accident and
    which parts of those vehicles were damaged in the occurrence complained of, the name and address of the person or entity who repaired each vehicle, and the date and cost of repairs. If the vehicles have not been repaired, state the present location of said vehicles, the days of the week, the time of day, and the places they may currently be seen and identify any photographs of the vehicles involved in the collision.
  19. Please state with specificity exactly how this accident took place and include in
    your answer, the date of the accident, the time of the accident, the location of the accident, where you vehicle was just prior to the accident, where the Plaintiff’s vehicle was just prior to the accident, how far away the Plaintiff’s vehicle was just prior to the impact, the speed of your vehicle just before the accident, the speed of the Plaintiff’s vehicle just before the accident, the speed of the vehicles upon impact, and the exact locations in relation to the roadway upon impact, if this was a chain reaction accident, identify the sequence of the impacts between the vehicles.
  20. State what investigation, if any, you did to ensure that the driver of your vehicle
    was a safe driver.



                                                             

Respectfully submitted,

                                                                                    MILLER & ZOIS, LLC

                                                                                                                                                                        Ronald V. Miller, Jr.
                                                                                    Empire Towers, Suite 615
                                                                                    7310 Ritchie Highway
                                                                                    Glen Burnie, Maryland 21061
                                                                                    (410)553-6000
                                                                                    (410)760-8922 (fax)