Plaintiff’s Third Set of Interrogatories

TO: Defendant
FROM: Plaintiff

COMES NOW, the Plaintiff, _______________________ and propounds Interrogatories upon the Defendant, ___________________, to fully, under oath, and in accordance with the Maryland Rule of Civil Procedure, Rule 2-421, subject to the instructions set forth below:

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  1. These Interrogatories are continuing in character so as to require you to file supplementary answers if you obtain further or different information before trial.
  2. Unless otherwise stated, these Interrogatories refer to the time, place, and circumstances of the occurrence mentioned or complained of in the Complaint.
  3. Where name and identity of a person is required, please state full name, home address and also business address, if known.
  4. 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 answer is made by 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.
  5. The pronoun “you” refers to the party to whom the Interrogatories are addressed and the parties mentioned in clause (d).
  6. “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 principle place of business, or if an individual, the present or last known home address, his or her job title or titles, by whom employed and address of the place of employment.


  1. With respect to each expert the defendant has retained and may expect to call at trial, state:
    1. Identity;
    2. Education, training, experience, and field or specialty;
    3. Subject matter of any investigation or study conducted by the expert;
    4. Whether any written reports were completed by the expert and the date of said reports;
    5. The person who has custody of any reports;
    6. Whether the expert has conducted any tests or experiments;
    7. Subject matter on which the expert is expected to testify;
    8. Substance of facts and opinions to which the expert is expected to testify;
    9. Summary of the grounds for each opinion;
    10. Hourly rate charged by the expert;
    11. Amount of fee charged by the expert on this case;
    12. Number of cases expert has consulted or otherwise been retained on by your lawyer’s firm, including identification of each such case;
    13. Number of cases the expert has consulted or otherwise been retained on by your insurance company, including identification of each such case;
    14. Identification of all cases in which the expert has testified in deposition;
    15. Identification of all cases in which the expert has testified at trial.
    16. Identification of all cases in which the expert has been excluded from testifying at trial.

Respectfully submitted,

Miller & Zois, LLC

Ronald V. Miller, Jr.
1 South St, #2450
Baltimore, MD 21202
(410)760-8922 (Fax)
Attorney for Plaintiffs

Certificate of Service

I hereby certify that a copy of the foregoing Second Set of Interrogatories was mailed, by first class, postage pre-paid, certified U.S. mail on the _____ day of ______________, 2014, to:

Joan Harrison, Esq.
State Farm
One W. Pennsylvania Avenue
Suite 500
Towson, Maryland 21204-5025

Ronald V. Miller, Jr.

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