Erie Interrogatories

Interrogatory No. 1: State your full name, address, date and place of birth, Social Security number, marital status, maiden name (if married), driver’s license number and state of issue, and any other names or aliases which you have used.

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Interrogatory No. 2: With respect to each of the past ten (10) years, and at the present time, state the names and addresses of each of your employers, the dates of commencement and termination of each employment, the reason for termination, a detailed description of work performed for each employment, your average weekly wages or earnings from each employment, and the names of your last supervisor at each of the employments identified in your answer to this Interrogatory.

Interrogatory No. 3: If you lost any time from your employment or occupation as a result of the injuries sustained in the occurrence, state precisely the dates of absence explaining why you were absent, the amount of wages or earning lost as a result of the occurrence, the date(s) you returned to work, for whom you returned to work, the wage at return, and the duties performed after return.

Interrogatory No. 4: State the full name and last known address of every person known to you or your attorney who was an eyewitness to all or part of the occurrence referred to in the Complaint, giving the location of each person at the time of the occurrence.

Interrogatory No. 5: State the full name and last known address of all persons who arrived at the scene of the occurrence within two (2) hours after the occurrence and the time of their arrival.

Interrogatory No. 6: Identify all persons whom you intend to call as experts at trial of this matter, attaching to your answers to these Interrogatories copies of their reports, setting forth their fields of expertise, and further stating the opinions to which they will testify and the facts upon which they will base their opinions, and identify all books and publications of whatsoever nature upon which they will rely.

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Interrogatory No. 7: State the amount you reported as earned income in your Federal Income Tax Returns for each of the past five (5) years, and the District in which the Returns were filed.

Interrogatory No. 8: If you contend that this Defendant or any agent or employee of this Defendant at any time made an admission against interest or made any statement adverse to this Defendant with respect to any issue involved in this litigation, state by whom the admission or statement was made, when it was made, whether it was made orally or writing, to whom it was made, and in whose presence the admission was made and the nature of the admission or statement.

Interrogatory No. 9: State with precision the nature and location of all bodily injuries suffered by you as a result of the occurrence, stating in detail the nature of all present complaints which you have as a result of the occurrence and whether any personal injuries are permanent.

Interrogatory No. 10: Name all hospitals, physicians, surgeons, dentists, and any other person or institution which has rendered treatment to you as a result of the occurrence for which this suit has been brought and state the dates, natures, and cost of such treatments.

Interrogatory No. 11: Give an itemized statement of all charges, expenses and losses (including property damage, if applicable) allegedly paid or incurred by you for which you intend to make claim as a result of the occurrence, including which of said charges, expenses, and losses have been paid, indicating when and by whom those charges, expenses, and losses were paid.

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Interrogatory No. 12: If you have ever suffered any injuries in any accident, or under any circumstances either prior or subsequent to the incident referred to in the Complaint, state the date and place of such injury, a detailed description of all the injuries you received, the names and addresses of any hospital, physician, surgeons, dentists, osteopaths, chiropractors, or any other medical practitioners rendering treatment, the nature and extent of recovery, and, if any permanent disability was suffered, the nature and extent of the permanent disability and if you were compensated in any manner for any injury, state the names and addresses of each and every person or organization paying such compensation and the amount thereof

Interrogatory No. 13: If you contend that a previous injury or condition was aggravated by the occurrence for which this suit has been brought, describe such previous injury or condition, stating the effects of the aggravation of your previous injury or condition, the names and addresses of all persons or institutions who treated or examined you for the previous injury or condition and the approximate dates of such treatments or examinations.

Interrogatory No. 14: If you know of the existence of any pictures, photographs, diagrams, or objects relative to the occurrence or its consequences, state the nature, subject matter, date produced or obtained, and the name and address of the present custodian of each. Interrogatory No. 15: If you consumed any alcoholic beverages of any type or any sedative, tranquilizer, or other drug, medicine, or pill during the twelve (12) hours immediately preceding the occurrence referred to in the Complaint, state the nature, amount, and type of item consumed, when it was consumed, and the amount of time over which it was consumed, and the names and addresses of any and all persons who have knowledge as to the consumption of those items.

Interrogatory No. 16: Give a detailed description of how you contend the accident occurred, specifically including but not limited to the respective speeds, positions, directions, and locations of the vehicles involved in the occurrence prior to, at the time of, and immediately following the occurrence, what traffic controls were in operation at the scene of the occurrence, when you first saw the vehicle operated by Defendant, the number of and sequence of collisions in the accident, what you did to avoid the collision, and including a statement containing the factual basis for the allegations in the Complaint.

Interrogatory No. 17: State what part of the vehicle you were driving at the time of the occurrence was damaged, and, if repair estimates were given or repairs made, the name(s) and address(es) of the person(s) who performed such estimates or repairs, the dates of such work and the costs thereof, attaching a copy of the estimate or bill for repairs, and if such vehicle is unrepaired, state the address at which and the hours when it may be seen.

Interrogatory No. 18: State the names and addresses of all persons who investigated the cause and/or circumstances of
the occurrence for you.

Interrogatory No. 19: State whether after reaching the age of 18 and represented by counsel, or having waived representation by counsel, you have ever been convicted of any crimes, other than for violations of the Motor Vehicle Laws, and, if so, set forth the nature of such crimes, the dates of each conviction and the name and address of the Courts wherein each conviction occurred.

Interrogatory No. 20: State whether prior to the occurrence, at the time of the occurrence, or since the occurrence, your driver’s license was or has been subject to any restrictions or was revoked or suspended, and state the nature of those restrictions and the reasons for the revocation or suspension.

Interrogatory No. 21: State the itinerary of the vehicle you were driving on the day of the occurrence referred to in the Complaint, including the owner of the vehicle, purpose of the trip, origin of the trip, the stops, the ultimate destination, stating the time of day for origin, the stops, and the time you expected to complete the trip.

Interrogatory No. 22: State whether you have within your control or have knowledge of any transcripts of testimony in any proceedings arising out of the occurrence, and if so, state the subject matter, the business address of the person recording that testimony, and the name and address of the person who has current possession of each such transcript of testimony.

Interrogatory No. 23: If you have ever made claim for any benefits under any insurance policy or against any person, firm, or corporation for personal injuries or physical condition heretofore listed in your answers to these Interrogatories, state the injury or condition for which such claim was made, the name and address of the person, firm, or corporation to whom or against whom it was made, the nature and amount of any payment received therefore and the date it was made.

Interrogatory No. 24: If you contend that a person not a party to this action acted in such a manner as to cause or contribute to the occurrence, give a detailed statement of the facts upon which you rely, including the names and addresses of those persons.

Interrogatory No. 25: State the names and addresses of all persons who have given written or oral statements concerning the occurrence, the dates those statements were taken, and the name and address of the person who has current possession of those statements, and attach to your Answers to these Interrogatories a copy of any such statement in your control given or made by this Defendant.

Interrogatory No. 26: State whether you are acquainted with or related to any persons or organizations named in your answers to these Interrogatories, state the length and nature of the acquaintance and/or relationship.

Interrogatory No. 27: State the names and last known addresses of any persons not identified in your other answers to these Interrogatories 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 knowledge about causation or damages.

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