PLAINTIFF’S SECOND SET OF INTERROGATORIES
TO: Defendant
FROM: Plaintiff
COMES NOW, the Plaintiff, ____________ and propounds Interrogatories upon the Defendant, __________________, to fully, under oath, and in accordance with the Maryland Rule of Civil Procedure, Rule 2-421, subject to the instructions set forth below:
INSTRUCTIONS
(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) Unless otherwise stated, these Interrogatories refer to the
time, place, and circumstances of the occurrence mentioned or
complained of in the Complaint.
(c) Where name and identity of a person is required, please state
full name, home address and also business address, if known.
(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 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.
(e) The pronoun "you" refers to the party to whom the
Interrogatories are addressed and the parties mentioned in clause
(d).
(f) "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
1. 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?
2. Set forth all facts upon which you intend to rely to support
your denial of Plaintiff's First Set of Request for Admission,
Request #12. Include in your answer the witnesses and medical
records you believe support your denial and the reasonable inquiry
that you made before denying this request.
3. Set forth all facts upon which you intend to rely to support
your denial of Plaintiff's First Set of Request for Admission,
Request #13. Include in your answer the witnesses and medical
records you believe support your denial and the reasonable inquiry
that you made before denying this request.
4. You have denied that the treatment given and the bill for services
rendered to Plaintiff were fair, reasonable, necessary, and causally
related to the car crash complained of in the Plaintiff's Complaint.
See Plaintiff First Set of Requests for Admission, Question and
Answer, #17 and #18. 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.
5. Do you believe that Plaintiff has been dishonest with anyone
regarding the car crash and the injuries he suffered? If so, state
with specificity what facts you believe he gave you that were
dishonest and why you hold that opinion.
6. Your request for admissions indicate that you do not believe
that “Plaintiff suffered injuries while fighting valiantly
for his country in World War II in the Battle of the Bulge.”
See Plaintiff's First Set of Request for Admission, Question and
Answer, #10. Set forth the reasonable inquiry that you made before
denying Request for Admission #10 and set forth all facts upon
which you intend to rely upon at trial to support your denial.
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 a copy of the foregoing Plaintiff’s Second Set of Interrogatories has been sent via U.S. Mail, first-class, postage prepaid, on the ______ day of ____, 20__, to:
Joan
I. Harrison, Esq.
State
Farm
H.
Barritt Peterson, Jr., & Associates
One
W. Pennsylvania Avenue
Suite
500
Towson,
Maryland 21204-5025
________________________
Ronald
V. Miller, Jr.
