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Sample Car Accident Interrogatories




JAMES KROL- Defendant

CASE NO. 24-C-02-00380

Plaintiff's Interrogatories To Defendant



Plaintiff, Ashley Burton, by her attorneys, Ronald V. Miller, Jr. and Miller & Zois, LLC, hereby propounds Interrogatories upon the Defendant, James Krol, to fully, under oath, and in accordance with the Maryland Rule of Civil Procedure, Rule 2-421, subject to the instructions set forth below:

Practice Tip

These are the interrogatories to be used in an auto accident case if you intend to file all 30 interrogatories at the same time. For reasons discussed on the sample interrogatories main page, you may want to serve multiple sets. We have a template for that on our interrogatories home page.

  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 auto accident and personal injuries 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.
  7. “Auto Accident” is defined as the car accident that occurred on April 6, 2007 as referenced in Plaintiff’s Complaint.
  1. Please state your full name, home address (and all addresses for the last five (5) years, social security number, date of birth, marital status and your employer's name and address. Include in your answer who was lived with you in the five (5) year period before the accident.
  2. If you contend that the personal injuries of Plaintiff was not caused by the collision with your vehicle, state with particularity the facts upon which you base your contention.
  3. Please state the name and address of your employer, your position and duties, and your wages at the time of the auto accident and at the present time.
  4. Please state in detail your itinerary on the date of the auto accident, including each place at which you were present, your length of stay at each such place, and a detailed account of whom you saw and what you did at each such place.
  5. Please identify all persons known to you to have personal knowledge of the facts pertaining to the occurrence, and indicate those who were eye witnesses, and state the substance of their knowledge and articulate their expected testimony.
  6. Please identify all persons (excluding attorneys) who investigated the cause and circumstances of this personal injury auto accident for you.
  7. Please identify all persons who arrived at the scene of the auto accident within one (1) hour after the auto accident.
  8. Please identify the motor vehicle you were operating at the time of your collision with the Plaintiff, including its make, year, registration number, and registered owner.
  9. If you were not the owner of the vehicle mentioned in Interrogatory No. 8, please identify its owner, stating his, her, or its relationship to you, whether you had his, her, or its permission to operate said vehicle, the purpose for which you were operating said vehicle, and how you came to be operating said vehicle. (Click here for more on this interrogatory.)
  10. Please identify all persons to whom you have given signed statements regarding the auto accident, the date thereof, and the name of the person in whose custody each is at this time.
  11. Please identify all persons who have given you signed statements regarding the auto accident or the personal injuries suffered by the Plaintiff in the accident.
  12. Please state whether your have within your possession or control photographs, plats, or diagrams of the scene of the auto accident or objects connected with said motor vehicle accident, stating what those objects are.
  13. Please give a concise statement of facts as to how you contend the car accident took place.
  14. If you contend that either Plaintiff acted in such a manner as to cause or contribute to his or her personal injuries, state all facts upon which you rely to demonstrate this.
  15. Please identify all expert witnesses who will be called at the trial of this case, the area of expertise of each, and a summary of the expected testimony of each.
  16. Please state whether you consumed any drugs, medicines, or alcoholic beverages within twenty-four (24) hours prior to said occurrence, the place where such drugs, medicines, or alcoholic beverages were obtained, the nature of the drugs, medicines, or alcoholic beverages, and the amount thereof.
  17. Please state whether you were under the care of a physician at the time of the auto accident. If so, please state the name and address of your physician, specify the illness or condition for which you were treated, and list any prescribed medication.
  18. Please state when and where you obtained your learner's permit and your driver's license, including whether such permit or license is or was subject to any restriction, and the nature of such restriction, if any.
  19. Please list all insurance agreements you have made regarding the vehicle you were operating at the time of the occurrence, including the name of the owner, the name of the insurance carrier, the policy number, the type of coverage, the amount of coverage (specifying its upper and lower limits) and the effective dates of said policy for the past five (5) years.
  20. Please state whether you had any other insurance policies in effect at the time of the auto accident covering bodily injuries caused to other person. If so, please provide all pertinent information, including the name of the insurer, the policy number, the type of coverage, the amount of coverage, specifying its upper and lower limits, and the effective dates of said policy. (Note: In Maryland, unlike other states, this is the only way to find out the a defendant's coverage.)
  21. Please list all prior motor vehicle accidents in which you have been involved, either with other persons or with property. Please include the name of any other driver or property owner involved, the location of the collision, the date and time of the collision, and disposition of the matter. (Click here for more on this interrogatory.)
  22. Please list all violations of the motor vehicle laws of the State of Maryland or any other jurisdiction with which you have been charged since you obtained your driver's license. (Click here for more on this interrogatory.)
  23. Please state whether your automobile insurance has ever been cancelled, and if so, state the name of the insurer and the reason for cancellation. (Click here for more on this interrogatory.)
  24. Please state whether the vehicle of the Plaintiff was moving at the time of the auto accident, and if so, state the direction and speed of said vehicle to the best of your recollection.
  25. Please state in detail which part of your vehicle came into contact with which part of the vehicle of the Plaintiff.
  26. If you and the Plaintiff had any conversation after the auto accident, please state the substance of any such conversation.
  27. Please state in detail all actions you took or attempted to take to avoid the auto accident.
  28. Please identify all persons who drove with you during the day of the occurrence, including their full name and current address and telephone number.
  29. If any members of your family or anyone else had any conversations with the Plaintiffs, please state to the best of your knowledge the place of such conversations and the nature of such conversations.

Respectfully submitted,

Miller & Zois, LLC

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

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