IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND

MANDY GLENN- Plaintiff

v

STEVENS APARTMENTS , et al. - Defendants,

* * * * *
         CASE NO. 24-C-04-109432 MT
 

INTERROGATORIES TO THE DEFENDANT FROM THE PLAINTIFF

TO: STEVENS APARTMENTS

FROM: MANDY GLENN

      Plaintiff propounds the following 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. Please identify the person or persons responding to these Interrogatories on behalf of the Defendant, and identify each person who has provided information in connection with these Interrogatories.
      2. Identify the owner of the parking lot and sidewalks in front of the premises
      3. Identify the party who was responsible for clearing the public areas of the neighborhood
      4. Identify any person not already named as a party to this lawsuit whom you contend caused or contributed to the occurrence complained of, including any architect, engineer, designer, contractor, subcontractor or others.
      5. Identify each person with whom you are aware that:
           a. Witnessed the incident or the events occurring immediately before or after the incident; and/or who
            b. Heard any statements made about the incident by any individual at the scene.
      6. Identify each employee with personal knowledge of the incident.
            a. For each such individual, identify his or her job title and job or function which was being performed by that individual at the time of the incident.
      7. Identify each person interviewed concerning the incident? For each such person, state:
            a. The date of the interview
            b. The substance of the interview.
If the interview was recorded and/or transcribed, a reproduction of the recording and/or transcript will suffice.
      8. Identify each and every written report made by any person concerning the incident.
      9. Please state, in your own words, what you believe happened to Plaintiff on the common walkway in front of the premises located at 7381 Green Mountain Court, Baltimore, Maryland on February 21, 2006 and include in your Answer the basis upon which you have formed that belief.
            a. Identify each person (excluding your attorney) who provided you with information which enabled you to respond to this Interrogatory.
      10. Identify any insurance agreement(s) under which any insurance business may be liable to satisfy part or all of any judgment which may be entered in this action, or to indemnify or reimburse you for payments made to satisfy the judgment, including in your answer the amount and limits of any such liability insurance coverage.
      11. Identify all persons whom you intend to call as expert witnesses at the trial of this case, and for each such expert, identify:
            a. The subject matter on which he or she is expected to testify:
            b. The substance of the facts and opinions to which he or she is expected to testify:
            c. A summary of the grounds for each opinion to which he or she will testify;
            d. The basis upon which he or she qualifies as an expert on the subject matter to which he or she is expected to testify.
      12. Please identify your correct legal entity and identify stating the date on which such entity was formed, the State of incorporation, the name(s) and address(es) of all officers, directors, general partners, limited partners and all other parties with any interest in your organization.
      13. Identify any previous or subsequent incidents of which you are aware which occurred in substantially the same manner as the incident complained of in this lawsuit which also occurred in the common areas of the Aspen Park neighborhood, Pasadena, Anne Arundel County, Maryland.
      14. Identify in detail any changes that have been made by you, or anyone on your behalf, as to the physical site of the accident or as to any warnings or signs relating thereto since the occurrence in question.
      15. Identify any procedures which you followed, at and before the time of the incident in question, concerning the inspection, repair and cleaning of the area where Plaintiff's injuries occurred.
16. Identify any warnings, whether verbal or written (such as by a sign, or otherwise) which were given to the Plaintiff, specifically, and/or to your homeowners, in general, before the accident concerning the condition which caused or contributed to the incident complained of in this lawsuit.
      17. Identify any admission(s) or declaration(s) against interest which you contend was made by the Plaintiff following the incident in question.
      18. Identify the date on which you were first notified of the fact that the parking lot and/or sidewalks had not been properly cleared of ice and snow in the area where the Plaintiff fell and which is the subject of this lawsuit and identify the manner by which you became aware of this information.
      19. At the time of Plaintiff's injury, do you contend that any person or entity other than you managed the premises on which Plaintiff alleges she was injured and, if so, state each and every fact on which you base the contention and identify each and every writing that supports the contention?
      20. At the time of Plaintiff's injury, do you contend that any person or entity other than you and your employees and agents was responsible for the maintenance of the premises on which Plaintiff alleges she was injured and, if so, state each and every fact on which you base your contention and identify each and every writing that supports the contention?
      21. Describe in detail any conversations any representative has had with the Plaintiff prior to or following the incident in question.
      22. What efforts were made by the Defendant to correct the condition which Plaintiff contends caused the occurrence in question after the accident in question?
      23. Please describe what training procedures, if any, are followed in the course of training of Defendant's employees with regard to homeowners and/or their guests slipping and/or falling. This includes any and all written material, slides, photographs, films, videotapes, etc. which Defendant utilizes in training its employees.


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

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