Evidence of the Defendant's Prior Accidents and/or Criminal Record
These are standard interrogatory questions that every lawyer handling a car accident case should ask. Just as standard, however, is the insurance company's defense lawyer's objection. You have to make sure you follow up and require reasonable responses to these interrogatory questions.
You might ask why car accident lawyers should focus on these kinds of interrogatories. After all, a conviction that does not involve moral turpitude is unlikely to be relevant in most car accident cases. Prior automobile accidents are also unlikely to be relevant. But the reason why these questions are still important is that defendants very often lie about both of these questions. This puts these matters at issue even if they otherwise would not be. The same logic applies to the question of whether the defendant has ever had his or her insurance policy cancelled. (This is an example of reaching as far as possible to attach a $5 million policy in a catastrophic brain injury case involving a young boy who was struck as a pedestrian in a crosswalk in Ocean City, Maryland by a young driver driving without a clear view from his windshield.)
Back to Car Accident Interrogatories (sample auto accident set)
See also Sample
Interrogatories (more model interrogatories)
See also Sample Discovery (examples of depositions, interrogatories, requests for admission and other discovery in personal injury cases)
See also Drafting Interrogatories:Thoughts for the Plaintiff's Lawyer
See also Maryland Personal Injury Attorney
Help Center (assistance for lawyers handling injury and malpractice cases)
See also Maryland Car Accident Lawyer Blog (blog about issues relating to personal injury auto accident and medical malpractice cases in Maryland)
See also Accident and Injury Lawyer Blog (national blog discussing personal injury cases and issues around the country)
See also Maryland Lawyer Blog (blog on Maryland law that focuses on personal injury issues)
See also Baltimore Personal Injury Lawyer Blog (discussion of Baltimore specific injury and malpractice cases)
See also Maryland Malpractice Blog (blog focusing on Maryland medical malpractice cases)
