Evidence of the Defendant's Prior Accidents and/or Criminal Record
Questions about prior accident and criminal history 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 defense counsel 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. In other words, it might not be admissible unless you lie about it.
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.)