You are requested to answer the following Interrogatories:
- These Interrogatories are continuing in character so as to require you to file supplementary answers if you obtain ftirther or different infonnation before trial.
- Where the name or identity of a person is requested, please state flu name, home address, and also business address if known.
- Unless otherwise indicated, these Interrogatories refer to the time, place and circumstances of the occurrence mentioned or complained of in the pleadings.
- 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 attorneys. When answer is made by a corporate defendant, state the name, address and title of the person supplying the information and making the aflidavit, and the source of his information.
- The pronoun “you” refers to the party to whom these Interrogatories are addressed and the persons mentioned in clause (d) above.
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- State your full name, address, date of birth, marital status, including spouse's name, social security number, present occupation, and present employer's name and address.
- Please identify each and every eyewitness to the occurrence, including the location of each witness, and whether you have any statement from any of such witnesses. If you do have statements from any witness, please indicate the nature and substance of each statement and attach hereto copies of any statements made by this Defendant.
- Do you know of any statement, conversation, comment, report or admission against interest or res gestae statement made by this Defendant at the time of, or following, the occurrence or facts relevant to any issue in this case? If your Answer is “Yes,” state the content of said statement, conversation, comment or report, the place where it took place, the name, address and telephone number to whom each statement was made, and in whose presence it was made.
- Have you in your possession or have you any knowledge of any object relating to the occurrence or to the injuries claimed to result therefrom or any photograph, picture, motion picture, drawing, diagram, plat, or other graphic or pictorial representation of the location of the occurrence, of the happening of the occurrence, of any objects related to the occurrence, or relating to the injuries claimed to result therefrom? maifaccidentfightIf your Answer is “Yes,” list each such item describing its subject matter, date or dates upon which taken or prepared, by whom taken or prepared, and name the person who now has custody or possession thereof. In accordance with Maryland Rule 3-421, please attach copies of all such objects, photographs, pictures, motion pictures, drawings, diagrams, plats, or other graphic or pictorial documents.
- Give a concise statement of the facts as to how you contend that the occurrence took place. Please state specifically whether you initially intended to turn left onto 209th Street, whether you had your left turn signal on and whether you then changed your mind and decided to turn right. If you contend that this Defendant acted in such a manner as to cause or contribute to the occurrence, give a concise statement of the facts upon which you rely.
- If you contend that a person or party other than this Defendant acted in such a maimer as to cause or contribute to the occurrence, give a concise statement of the facts upon which you rely.
- State with precision the nature and location of the bodily injuries suffered by you, if any, the nature of any present complaints and specify which of your injuries you contend are permanent in nature.
- State the name and address of all physicians, hospitals or other health care providers which have examined, treated, diagnosed you or engaged in any consultation with any other physician concerning you in connection with your injuries or complaints herein. As to each physician, hospital or other health care provider, describe in detail the examination, consultation, treatment, diagnosis or prognosis, including the dates thereof In accordance with Maryland Rule 3-421, please attach copies of all records and bills from all health care providers.
- For each and every injury you allege you sustained in this accident, please state whether you have ever had any prior discomfort, complaints or problems in that area, and identify fully all health care providers who examined or treated you, the nature of the treatment and the date(s) thereof In accordance with Maryland Rule 3-421, please attach copies of all records and bills from all health care providers. [Big interrogatory for MAIF: trying to get at your preexisting injuries.]
- Name all physicians, hospitals, or other health care providers which have examined or treated you for any injury, disability or illness for the past five (5) years including but not limited to any family doctor, general practitioner or clinic, and the approximate dates and nature of such treatments, excluding examinations and treatments connected with the occurrence.
- On what date did you return to employment after the occurrence, by whom were you employed, and what were your duties and wages?
- Give an itemized statement of the charges, expenses and losses paid or incurred by you as a result of the occurrence, including any claim for the reasonable value of medical or other services rendered to you, any claim for loss of wages or income, both past and future, and any future anticipated charges, claims, expenses and losses. In accordance with Maryland Rule 3-421, please attach copies of all documents in support of each claim.
- State the name and address of any and all persons whom you expect to call as an expert witness at the trial of this case. As to each expert named herein, 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, a summary of the grounds for each opinion, and attach hereto copies of all reports received from each expert witness.
- If you contend that you were unable to pursue any of the activities in which you were engaged prior to the occurrence, state in detail the basis and extent of your claim in this regard.
- State specifically whether you have received any injury in any accident or occurrence previous to the date of this occurrence or subsequent thereto. For each such incident, provide details, including the date and place of the occurrence, nature of injuries sustained, names and addresses of parties involved, claim and/or case number, name and address of any and all health care providers, and the dates and nature of treatment rendered. Please also attach copies of any pleadings, complaints, Answers to Interrogatories, Response to Request for Production of Documents, settlement releases or documents for any litigation and all medical records relating to all treatment for any such prior or subsequent injuries pursuant to Maryland Rule 3-421.
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