Example Dog Bite Interrogatories
MARY ELIZABETH WORTHINGTON
MARGARET DANERO, et al.
PLAINTIFF'S INTERROGATORIES TO DEFENDANT
TO: MARGARET WORTHINGTON, Defendant
FROM: MARY ELIZABETH DANERO, Plaintiff
Now comes Plaintiff Margaret Worthington ( "Plaintiff"), by and through his attorneys, Ronald V. Miller, Jr. and Miller & Zois, LLC, and hereby requests that the Defendant, Margaret Worthington, submit responses to these interrogatories.
Unless otherwise stated the subject matter of these Interrogatories is a dog attack that occurred on January 3, 2021 at the Victory Park Park at Greenhouse Meadows apartment complex located at 875 Victory Park Drive, Baltimore, Maryland 21228.
(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) If the interrogatory asks for 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, his attorney's. When an answer is made by a 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 principal place of business, or if an individual, the present or last known home address, his or her job title or titles, employer, and address of the place of employment.
(g) The "dog" mentioned in these interrogatories is the "dog" that attacked Plaintiff on January 3, 2021 at the Victory Park Park at Greenhouse Meadows apartment complex located at 875 Victory Park Drive, Baltimore, Maryland 21228.
(h) The term "occurrence" refers to the dog attack referenced in the Complaint that occurred on January 3, 2021, at the Victory Park Park at Greenhouse Meadows apartment complex located at 875 Victory Park Drive, Baltimore, Maryland 21228.
(i) The term "your apartment" refers to the apartment you were leasing on January 3, 2021 at the 875 Victory Park Park at Greenhouse Meadows apartment complex located at 875 Victory Park Drive, Baltimore, Maryland 21228.
(j) The term "attack" includes but is not limited to "jumping on the plaintiff."
State your full name, present address, birthdate, place of birth, social security number, marital status, maiden name (if married female), and any other names or aliases which you have used.
Give a detailed statement of the facts as to how you contend that the "occurrence" took place, to include any facts upon which you intend to rely upon in support of any defense.
Please state whether you were the owner of the dog and/or otherwise had possession and control of the dog involved in the attack on January 3, 2021. If you were not the owner of the dog, please identify who was the owner of the dog.
Please state the breed and size of the dog you owned and/or that was in your possession and control on January 3, 2021.
Please indicate whether it was your custom and practice to keep your dog on a leash when leaving your apartment from 2016 up until January 3, 2021.
Please state whether you were aware of any rules, policies, or procedures from Victoria Park at Greenhouse Meadows that would have required you to keep your dog on a leash when leaving your apartment from 2016 until today.
Please state whether you were aware of any rules, policies, or procedures from any other person or entity besides Victoria Park at Greenhouse Meadows that would have required you to keep your dog on a leash when leaving your apartment from 2016 until today
Please state whether from 2016 until today Victoria Park at Greenhouse Meadows or any other entity required you to carry renters insurance if you owned a dog.
Please state whether you had renters insurance that was in effect on January 3, 2021. Please include in your response the name of the insurance company, the name of your agent, any claims numbers that a relevant to the incident, as well as the names of any adjusters and their contact information. [Note: this is often the most important interrogatory our lawyers ask when the defendant is not the homeowner. Sometimes, we are forced to file a lawsuit to see if the defendant in a dog bite lawsuit has insurance. If they do not, it is often not sensible to proceed with the suit.]
Please state the policy limits for any renters insurance that was in effect on January 3, 2021.
Please list each document and describe the contents of the document that you believe may be in anyway related to the incident.
If you contend that the Plaintiff, or any other person or thing, either caused or contributed to the occurrence, give a complete statement of the facts upon which you rely.
Identify all experts you intend to call as witnesses, and whose reports you intend to mention and/or introduce at trial or in any Motion, including his/her area of expertise, and identify and attach to your Answers all written reports prepared by said experts, and indicate the content of any and all opinions reached by said experts and the factual basis for each such opinion and the amount of compensation paid to each such expert.
Name all persons who investigated the cause and circumstances of the occurrence and Plaintiff's injuries and damages for you and identify any reports prepared by such persons and the current custodian of said reports.
Identify any documents and recordings including, but not limited to, pictures, photographs, PowerPoint presentations for use at trial, demonstrative exhibits, computer-generated exhibits, visual aids, overlays, employment records, plats, visual recorded images, audio recordings, diagrams, and objects relative to the occurrence and the scene of the occurrence, as well as Plaintiff's physical condition. Identify the substance of the item, the date obtained, what is depicted within the item, and the name and address of the present custodian of each item.
Please state all actions that you took on the day of the occurrence to prevent the dog that attacked Plaintiff from attacking Plaintiff.
Did the dog that attacked Plaintiff have a dog license? If so, then please state the license number, the date the license was obtained, and the issuing authority for the dog license.
State the names and addresses of any person or persons who have personal knowledge of facts material to the cause or circumstances concerning the happening of the occurrence and the injuries, losses, and damages allegedly sustained in the occurrence, stating whether the person(s) identified has/have knowledge about causation or damages.
Name those persons, including yourself, who have provided to your employer or any insurance carrier, or have given you, written, oral or recorded statements concerning the occurrence, and indicate the date and time of each such statement, the author of each such statement and the current custodian of same.
If you contend that the injuries and disability now complained of by the Plaintiff were the result of prior or subsequent injuries or illnesses or not caused by the occurrence, give a concise statement of the facts upon which you rely and identify the names of all experts who have provided opinions regarding such contention and attach the written reports from said experts to your answers.
Please state your itinerary for the 8 hours preceding the dog attack on January 3, 2021, to include your location, what activity you were engaged in, and identify any other persons who were present.
Please list every civil, criminal, traffic, and administrative matter wherein you were a party to include a complete caption, nature of the case, case number, city, county, and state where the action was located, date of the proceeding, name and address of all parties and their attorneys, and the outcome of each case.
State whether you have or have had any disability, illness, disease or injury for which you have been examined or treated by any physician or hospital that would have prevented you from keeping the dog that attacked the Plaintiff from attacking the Plaintiff.
If at the time of the accident, you were insured through a policy including but not limited to liability, homeowners, or umbrella coverage, either in your own name or through the name of some other person, state:
- the name and address of the insurer issuing the policy;
- the number of the policy;
- the named insured under the policy;
- the location/address of the property that was insured under the policy; and
- the nature and extent of the coverage which protects you against the risks of this suit.
If you or your attorneys know, or have reason to believe, that the company issuing any policy which would protect you from the risk sued hereon, has some grounds for denying, or limiting coverage under the policy, explain the nature and extent of your knowledge or belief.
If you contend that any of the medical treatment (to include each medical bill) received by the Plaintiff in the past, or projected costs for future medical care, was/is unreasonable, unnecessary, excessive, or not causally related to the automobile collision, please state the factual basis for this contention, to include the exact date of medical treatment/ bill, nature of medical treatment and name of the medical provider, and identify all of the witnesses who will provide testimony on this issue to include any expert witnesses and their opinions.
State the content of any lay opinion that you are aware of or intend to elicit from any person who is in any way associated with the incident. Please indicate the name and address of the person with such opinion and the exact date and time said opinion was reached.
If you intend to introduce any medical reports or opinions into evidence at trial without the presence of the medical provider or expert, please identify each such report, the author of same, the date the report was prepared, the current custodian of the report, and the compensation which you paid to any experts for the preparation of the said report(s).