IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND
Patrick Jackson- Plaintiff v Brody Transportation - Defendant |
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CASE NO.: 06-C-00-1234 |
PLAINTIFF'S INTERROGATORIES TO DEFENDANT TRUCK DRIVER
TO: Defendant Truck Driver
BY: Plaintiff
Plaintiff, by and through his attorneys, Laura G. Zois and Miller & Zois, LLC, requests that Defendant (hereinafter "Defendant Truck Driver") answer the following Interrogatories fully, under oath and in accordance with the Maryland Rules 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 Plaintiff's Complaint.
(c) Where name and identity of a person is required, please state full name, home address and 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, attorneys. When an answer is made by corporate defendant, please state the name, address and title of the person 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 a: (a) person, means to state his or her full name, telephone number, present or last known home address, his or her job title or titles, by whom employed and address of the place of employment; (b) public or private corporation, partnership, association, or other organization, or to a governmental agency, means to state its full name and present or last known pertinent business address and phone number.
INTERROGATORIES
1. State your full name, current address, date of birth, social security number, driver's license number and state which issued the driver's license, and both work and home address(es) for the last ten (10) years.
2. Identify any individual you are aware of that has personal knowledge of the facts and circumstances of this case, including eyewitnesses, passengers, people claiming to be eyewitnesses and any individuals who arrived on the scene within five (5) hours after the occurrence.
3. If anyone investigated this matter for you, including medical experts, private investigators or insurance adjusters, state their name(s) and address(es), and state whether such investigation was reduced to writing, and the substance of their investigation and findings. If said investigator obtained any signed, recorded, transcribed or oral statement from any individual, identify the person who gave the statement and the present custodian of such statement.
4. If you know of the existence of any pictures, photographs, plats, visual recorded images, police reports, 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.
5. State whether you have within your possession or control, or have knowledge of, any transcripts of testimony, in any proceedings arising out of the occurrence. If so, state the date, the subject matter, the name and address of the person who has present possession of each said transcript of testimony.
6. Do you know of any statement, conversation, comment, or report made by any party to this lawsuit or witness, including the Plaintiff, made at the time of the occurrence or following the occurrence, concerning the occurrence or facts relevant to any issue in this case? If your answer is "yes," state the content of such statement, conversation, comment, or report, the place where it took place, and the custodian of such statement.
7. State the name and specialty of all experts whom you propose to call as witnesses at trial, and for each expert state the subject matter on which the expert is expected to testify, the substance of the findings and opinions to which the expert is expected to testify and attach to your Answers copies of all written reports of each such expert.
8. If you contend that any other entity or person, a party to or not a party to, this lawsuit, was responsible for the Plaintiff = s injuries, identify such person, persons or entities, and give a concise statement of the facts upon which you rely.
9. Please identify any policy of insurance or any insurance agreement that was in affect at the time of the accident and identify the type of policy, the identity of the insurance company the policy number and the policy limits and coverage afforded under the policy or policies and if your insurance has ever been cancelled or lapsed, please identify the carrier and when the cancellation or lapse occurred.
10. If you were acting within the scope of your employment at the time of the truck accident, please indicate whether or not you were required to file a report within the regular course of business as a result of the truck accident, identify your employer and state what you were doing on behalf of your employer at the time of the truck accident.
11. Identify the property damage done to each vehicle and/or piece of equipment as a result of the truck accident, and which parts of those vehicles and/or equipment 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.
12. Were you the owner of the vehicle or trailer involved in this occurrence? If no, state the name and address(es) of the owner(s), whether you had the permission of the owner of the vehicle and/or trailer to operate or use the equipment and the purpose for which you were operating or using the equipment.
13. State whether you or the driver of your vehicle consumed any alcoholic beverages or drugs, prescription, over the counter, or illicit, within eight (8) hours prior to the alleged occurrence, and if the answer is in the affirmative, state where they were obtained and consumed and the nature and amount thereof.
14. State the full itinerary of your vehicle, stating the place and time of the beginning of the trip, the place and time and duration of each stop, the route taken, the destination and the anticipated time of arrival at that destination.
15. 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 your vehicle was just prior to the accident, where the vehicles were just prior to the accident, how far away the Plaintiff's vehicle was from you just prior to the impact, the speed of your vehicle just before the accident, the speed of Plaintiff's vehicle just before the accident, the speed of the vehicles upon impact, and the exact locations in relation to the roadway before, and upon impact, and where the vehicles came to rest. If this was a chain reaction accident, identify the sequence of the impacts between the vehicles.
16. Did you have any conversations with the Plaintiff, witnesses to the truck accident, or investigators at the scene of the truck accident or anytime after the truck accident? If so, state the substance of such conversations.
17. Please list all prior accidents in which you have been involved, either with other persons or with property, and all violations you have received. Please include the name of any other driver or property owner involved, the location of the collision, the date and time of the collision, and disposition of the matter.
18. Since your eighteenth (18 th ) birthday, have you been convicted of a felony?
19. Do you contend that the Plaintiff was contributorily negligent or assumed the risk of his or her injuries? If so, state the facts upon which you rely.
20. Please give a complete history of your driving record, both personal and professional, for the last fifteen (15) years, including but not limited to, traffic citations, and inspection citations.
21. Identify any medical doctor, medical facility or healthcare professional you have seen in the last five (5) years for any reason, including regular check-ups or work related evaluations, and identify the healthcare provider by name, address and phone number.
22. Please state your employment history, supervisors, type of work and the length of time you were employed at each place of employment for the past ten (10) years.
23. State whether there has been a surveillance of Plaintiff's activities from the date of the incident referred to in Plaintiff's Complaint to the present, and if so, state:
(a) The names and addresses of the persons conducting said surveillance, and the date or dates said surveillance was conducted.
(b) Whether Defendant Pakacki is in possession of surveillance reports, and if so, please state the names and addresses of those persons in possession of said reports.
(c) Whether Defendant is in possession of surveillance photographs, slides or motion pictures depicting Plaintiff's activities. If so, please state the names and addresses of those persons in possession of said reports.
24. Please state whether you completed a driver's accident report form detailing the incident of March 12, 2004?
25. Identify any training manual or safety manual you were given by any of the Defendants in this case.
26. Disclose any interview process you went through before being hired by any Defendant in this case, including, but not limited to, any application for employment; driving test; medical evaluation; face-to-face, electronic or telephonic interview; verification of insurance information; licensing; and safety history.
27. Please describe the nature of your relationship with each of the named Defendants.
Respectfully submitted,
MILLER & ZOIS, LLC
Laura G. Zois
Empire Towers, Suite 1001
7310 Ritchie Highway
Glen Burnie, Maryland 21061
(410) 553-6000
(410) 760-8922 ( facsimile)
Attorney for Plaintiff
MILLER & ZOIS, LLC
Ronald V. Miller, Jr.
Laura G. Zois
Empire Towers, Suite 1001
7310 Ritchie Highway
Glen Burnie, Maryland 21061
(410) 553-6000
(410) 760-8922 ( facsimile)
Attorney for Plaintiff
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