Sample Geico Interrogatories
(interrogatories propounded by GEICO)
Pursuant to Rule 2-421, you are required to answer the following interrogatories within 30 days or within the time otherwise required by court order or by the Maryland Rules.
(a) In accordance with Rule 2-421(b), your response shall set forth the interrogatory, and shall set forth the answer to the interrogatory "separately and fully in writing under oath" or "shall state fully the grounds for refusal to answer any interrogatory." The response shall be signed by you.
(b) Also in accordance with Rule 2-421(b), your answers "shall include all information available" to you "directly or through agents, representatives, or attorneys."
(c) Pursuant to Rule 2-401(e), these interrogatories are continuing. If you obtain further material information before trial you are required to supplement your answers promptly.
(d) If pursuant to Rule 2-421(c), you elect to specify and produce business records of yours in answer to any interrogatory, your specification shall be in sufficient detail to enable the interrogating party to locate and identify the records from which the answer may be ascertained.
(e) If you perceive any ambiguities in a question, instruction, or definition, set forth the matter deemed ambiguous and the construction used by you in answering.
(f) Where knowledge or information of a party is requested, such request includes knowledge of the party's agents, representatives, and attorneys, unless privileged. When answer is made by corporate plaintiff(s), state the name, address and title of the person supplying the information and making the affidavit and the source of this information.Definitions
In these interrogatories, the following definitions apply:
(a) Document includes electronically stored information and any writing, drawing, graph, chart, photograph, sound recording, image, and other data compilation, in a tangible form, electronic form, or otherwise, stored in any medium from which information can be obtained, translated, if necessary, through detection devices into reasonably usable form.
(b) Identify, identity, or identification, (1) when used in reference to a natural person, means that person's full name, last known address, home and business telephone numbers, and present occupation or business affiliation; (2) when used in reference to a person other than a natural person, means that person's full name, a description of the nature of the person (that is, whether it is a corporation, partnership, etc. under the definition of person below), and the person's last known address, telephone number, and principal place of business; (3) when used in reference to any person after the person has been properly identified previously means the person's name; and (4) when used in reference to a document, requires you to state the date, the author (or if different, the signer or signers), the addressee, the identity of the present custodian of the document, and the type of document (e.g., letter, memorandum, telegram, or chart) or to attach an accurate copy of the document to your answer, appropriately labeled to correspond to the interrogatory.
(c) Person includes an individual, general or limited partnership, joint stock company, unincorporated association or society, municipal or other corporation, incorporated association, limited liability partnership, limited liability company, the State, an agency or political subdivision of the State, a court, and any other governmental entity.
(d) The term Occurrence, unless otherwise indicated, means the collision or other event complained of in the pleadings.
(e) The pronoun you refers to the party to whom these Interrogatories are addressed.Interrogatories
- Identify yourself and state all names by which you have been known, your date of birth, address, social security number, your marital status, and identify your spouse.
- Give a concise statement of the facts as to how you contend the occurrence took place. If the occurrence involved the use of any vehicles, identify the registered owner of each vehicle and state the respective speeds, positions and directions of travel of the vehicles during the approach to, at the time of, and immediately after the occurrence.
- State whether you were in the process of entering or leaving a lane of travel at the time of the occurrence and whether you had your turn signal on prior to or at the time of the occurrence
- State whether your vehicle was at or near a traffic signal at the time of the occurrence and, if so, whether the signal had a red, yellow, green or turn arrow indicated immediately prior to the occurrence.
- State the position of Defendant's vehicle compared to your vehicle immediately prior to the collision and whether Defendant changed lanes immediately prior to the collision.
- If you contend that Defendant was negligent in causing or contributing to the occurrence, set forth all facts upon which you base your contention.
- State the names and addresses of all persons who were at or near the scene, or who arrived on the scene within two hours after the occurrence, specifying those persons you contend were eyewitnesses to any part of the occurrence.
- Describe in detail any signed or unsigned statements or recorded statements, made by the defendant(s) or the defendant(s) agent or employee.
- State the names of all persons who have given you statements, or from whom you have statements reduced to written or recorded form, the dates of such statements, the names of persons who procured such statements, and the names of the persons who have custody or possession of such statements.
- Give a brief description of the subject matter of any photographs within your possession or control which show the injuries complained of, vehicles involved in the occurrence, the scene of the occurrence or any objects connected therewith; state the dates on which such photographs were taken, and the name and address of the photographer.
- State in detail the nature of all bodily injuries sustained by the plaintiff as a result of the occurrence, and state which injuries, if any, are due to aggravation of any condition existing prior to the occurrence.
- State the names and addresses of all physicians, institutions, or other medical providers, which have examined you or given medical treatment to you for injuries claimed as a result of the occurrence, including the dates and nature of such treatments, and whether you are presently still treating with any healthcare provider.
- State the names and addresses of all mental or health care providers, including your primary care provider, which have examined and treated you for any cause for the past ten (10) years, and the dates and nature of such treatments.
- State specifically whether you received any mental or physical injuries in any accident or occurrence previous to this occurrence, or subsequent thereto. If so, state the details, including date, place of occurrence, nature of injuries sustained, and the names and addresses of attending mental or health care providers and dates of all examinations or treatments for such injuries.
- State whether you were involved in any other motor vehicle accident within five (5) years of the occurrence. If so, state the details, including date, place of occurrence, identity of other drivers, whether you or your vehicle sustained any damage.
- State whether you ever had, prior to the occurrence, complaints of pain or symptoms of disease or injury in those parts of your body, which were injured in the occurrence. If so, state when, describe the complaints or symptoms, and state the names and addresses of all mental or health care providers who treated or examined you for such complaints or symptoms, and the dates of such examinations or treatments.
- Identify each person whom you expect to call as an expert witness at trial, state the subject matter on which the expert is expected to testify, state the substance of the findings and opinions to which the expert is expected to testify and a summary of the grounds for each opinion, and, with respect to an expert whose findings and opinions were acquired in anticipation of litigation or for trial, summarize the qualifications of the expert, state the terms of the expert's compensation, and attach to your answers any available list of publications written by the expert and any written report made by the expert concerning the expert's findings and opinions. (Standard General Interrogatory No. 2.)
- If you have any present complaints on account of the injuries received in the occurrence, state in detail the nature of the present complaints and what injuries, if any, are alleged to be permanent, and what activities, if any, you are now unable to perform as a result of the occurrence, which you did perform prior to the occurrence.
- Did you lose any time from employment as a result of the occurrence? If so, state precisely the dates of the absences from employment, the amount of wages lost on account thereof, and the names and addresses of the employers from whom said wages or income would have been received, and state whether or not you contend there is a continuing wage loss or diminished income related to the occurrence.
- Give an itemized statement of all expenses paid or incurred by you as a result of the occurrence. Attach to your Answers copies of all bills and receipts.
- If, since reaching the age of majority, you have ever been convicted of any crime, other than minor traffic violations, state the nature of the crime, the dates of conviction, and the names and locations of the courts resolving any matter related to such crimes.
- State whether you have within your control, or have knowledge of any transcripts of testimony in any proceeding arising out of the occurrence. If so, state the date and the subject matter of each transcript and state the name and address of the person who has present possession of each said transcript of testimony.
- If you contend that this party, or any of his/her agents, servants or employees, made any admission or statement against interest, set forth the identity of the individual making the alleged statement, the date, time and substance and location in which the alleged statement was made, and all witnesses thereto.
- State the itinerary of your vehicle in the four (4) hours prior to the occurrence, including the time and place of the beginning of the trip, the time and duration of each stop, the place of destination, and the expected time of arrival.
- State whether you consumed or inhaled any alcoholic beverages, medications or drugs within the twenty-four (24) hour prior to the occurrence, the places where such alcoholic beverages, medications or drugs were obtained, and the nature and amount thereof.
- State what part of your vehicle was damaged, and if it was repaired, the name and address of the person who performed such repairs, the dates of such work, and the cost thereof. If the vehicle has not been repaired, state the address and the hours at which time it may be seen.
- Outline in detail the work schedule, physical or other activities for the plaintiff for the twenty-four (24) hour period immediately preceding the occurrence, including each place, address or location where you were within the twenty-four (24) hours immediately preceding the occurrence.
- If any person, firm, corporation or governmental agency has a subrogated interest in any item of damage you have claimed in this action, including Medicare or Medicaid, state the name and address of the firm, person, corporation or governmental agency, the nature of the interest, and the amount of its interest.
- State the names and addresses of all persons not heretofore named in your Answers to the Interrogatories who have personal knowledge of facts concerning the happening of the occurrence, your injuries, losses and damages, or who have investigated the occurrence for you and summarize your understanding of each such person's knowledge.
- List by case name, court, and docket reference, all litigation, workers compensation claims, health claim arbitration or social security benefits claims which you have filed prior to, and subsequent to, this action.