Sample Plaintiff's Answers to Defendant's Interrogatories

interrogatoryanswers

Now comes Plaintiff, Anne Powers, by her attorneys, Ronald V. Miller, Jr., Laura G. Zois, and Miller & Zois, LLC and hereby answers Interrogatories propounded upon her by Defendant, James C. Infada, as follows:

(a) The information supplied in these Answers is not based solely on the knowledge of the executing party, but includes the party's agents, representatives and attorneys unless privileged.

(b) The word usage and sentence structure is that of the attorney and does not purport to be the exact language of the executing party.

Interrogatories

Interrogatory No. 1: Give a concise statement of facts as to how you contend the accident took place.

ANSWER TO INTERROGATORY NO. 1: On May 22, 2003 Plaintiff was operating her vehicle on Maryland Route 152 near its intersection with Reckord Road. Plaintiff brought her vehicle to a complete stop due traffic stopped in front of her. As she was stopped, the Defendant hit her from behind and forced her vehicle forward.

Interrogatory No. 2: Identify all eyewitnesses and the location of each at the time of the accident.

ANSWER TO INTERROGATORY NO. 2: Mr. Kevin McGinnis, (410) 848-4303, (410) 446-8519 was a witness to the occurrence. Plaintiff is unaware of any other eyewitnesses to the occurrence other than the parties and her son who was a passenger in her vehicle.

Interrogatory No. 3: Identify all persons who were at or near the scene.

ANSWER TO INTERROGATORY NO. 3: Immediately after the accident, Plaintiff, her son and the Defendant were present at the scene of the accident, thereafter, the Defendant left the scene. These was another individual at the scene as identified above.

Interrogatory No. 4: Identify all persons who arrived at the scene within two (2) hours after the accident.

ANSWER TO INTERROGATORY NO. 4: Trooper Wheeley of the Maryland State Police arrived on the scene within two hours of the occurrence.

Interrogatory No. 5: Identify all persons who have given you statements, or from whom you have statements reduced to written or recorded form, the dates of such statements, the identity of persons who procured such statements, and the identities of the persons who have custody or possession of such statements. Attach hereto a copy of any signed statement, or a recorded statement, under your control, made by the Defendant(s), or the Defendant's agent or employees.

herniateddisinterrogatories

ANSWER TO INTERROGATORY NO. 5: None.

Interrogatory No. 6: State whether you have or have knowledge of any photographs, plats, diagrams or objects indicating anything relevant to the issues of this case. If so, please indicate which of the above, the date thereof and the identities of the persons who procured the same, and the identities of the persons having possession of the same.

ANSWER TO INTERROGATORY NO. 6: Plaintiff's attorney is in possession of photographs of the damage to her vehicle and photographs following her thoracic outlet surgery.

Interrogatory No. 7: State in detail the nature of all bodily injuries sustained by you as a result of the accident, and state which injuries, if any, are claimed to be an aggravation to any condition that existed before the accident.

ANSWER TO INTERROGATORY NO. 7: As a direct and proximate result of the Defendant's negligence, Plaintiff sustained injuries to her neck, back, knees, head, thoracic outlet syndrome, radiating numbness, tingling and pain into her upper and lower extremities, a herniated cervical discs requiring a discectomy and fusion at three levels.

Interrogatory No. 8: Identify all physicians and institutions which have examined you or given medical or other treatment to you for injuries claimed as a result of the accident, including for each, the dates and nature of such treatments.

ANSWER TO INTERROGATORY NO. 8: See Answer to Interrogatory #15 and records produced by Plaintiff.

Interrogatory No. 9: Identify all physicians and institutions which have examined and treated you for any cause for the past five (5) years, and the dates and nature of such treatment.

ANSWER TO INTERROGATORY NO. 9: See Answer to Interrogatory No. 10. Plaintiff's family physicians are Dr. Linder and Dr. Summer, her gynecologist is Dr. Kulkarni. She was occasionally admitted to various emergency rooms for dehydration, pain from the accident, and pneumonia. Plaintiff may have been seen for other unrelated issues; however, she was never checked for neck pain before the accident.

Interrogatory No. 10: Identify all persons, firms or corporations you expect to call as expert witnesses at the trial of this case and state the subject matter upon which each such expert is expected to testify, the substance of such expert's findings and the opinions to which the expect is expected to testify, a summary of the grounds for each such opinion, and attach to your answers to these Interrogatories a copy of any and all written reports made by each such expert concerning these findings and opinions.

ANSWER TO INTERROGATORY NO. 10:

Representatives and doctors from Franklin Square Hospital; including, Lawanda Summers, M.D., Edward Carter, M.D., are experts in the field of emergency medical treatment; their representatives are expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. The doctors' opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents.

Advanced Radiology; Jeffrey Rose, M.D.; and representatives are experts in the field of interpretation of diagnostic testing; the representatives are expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. The doctors' opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents.

Rafiq Patel, M.D., is an expert in the field of general medicine and orthopaedics; he is expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. The doctors' opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents.

Michele T. Cerino, M.D., is an expert in the field of thoracic surgery; she is expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. The doctor’s opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents.

Representatives and doctors from Harford County Ambulatory Surgical Center are experts in the field of pain management; the representatives are expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. The doctors' opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents.

Representatives and doctors from Chesapeake Medcare Services are experts in the field of pain management; the representatives are expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. The doctors' opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents.

Avraam Karas, M.D., is an expert in the field of orthopaedics and thoracic and outlet surgery; he is expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. The doctors' opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents.

Representatives and doctors from Rosen-Hoffberg Rehabilitation and Pain Management Associates are experts in the field of medical rehabilitation, physical therapy, and pain management; the representatives are expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. The doctors' opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents.

Representatives and doctors from Upper Chesapeake Medical Center are experts in the field of emergency medicine; the representatives are expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. The doctors' opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents.

Abdallah J. Helou, M.D., is an expert in the field of orthopedics and thoracic outlet surgery; he is expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. The doctors' opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents.

Representatives and doctors from Good Samaritan Hospital are experts in the field of general medicine; the representatives are expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. The doctors' opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents.

Henry A. Spindler, M.D., is an expert in the field of rehabilitation medicine and electromyography; he is expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. The doctors' opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents.

Mid-Atlantic Neurosurgical Associates, P.A., Agha S. Khan, M.D., and their representatives are experts in the field of orthopedics and neurosurgery; the representatives are expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. The doctors' opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents.

Rakesh K. Mathur, M.D., is an expert in the field of internal medicine, anesthesiology, and critical care; he is expected to testify at trial as to the care and treatment rendered to the Plaintiff following the auto accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. Dr. Mathur is also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of the personal injuries she suffered in the auto accident; future medical expenses and treatment which are reasonably expected in occur in the future. The doctors' opinions are based upon their review of Ms. Powers’ medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents.

Robert A. Johnson, M.D., is an expert in the field of orthopaedic surgery; he is expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. Dr. Johnson's opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents.

Joel D. Formosa, M.D., is an expert in the field of orthopaedic surgery; he is expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. The doctors' opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents.

Richard Trinkes, M.D., is an expert in the field of orthopaedics; he is expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. The doctors' opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents.

Kevin Strauss or some other individual will be called as an expert in the field of vocational rehabilitation; they are expected to testify as to the extent of the Plaintiff's ability to be re-trained in a career suitable to her skills and ability to learn a new trade, and the costs associated with such retraining, loss of earnings capacity and any losses she may incur.

Thomas Bonery is an expert in the field of economics; he is expected to testify as to the present day value of Plaintiff's loss of earning capacity and future lost wages.

Interrogatory No. 11: If you have any present complaints on account of the injuries received in the accident, state in detail the nature of the present complaints, and what injuries, if any, are alleged to be permanent.

ANSWER TO INTERROGATORY NO. 11: She still continues to have complaints of pain in her neck, back, and arms. She does have pain in her legs on occasion. She also have headaches. She has scarring from her thoracic outlet surgery and her neck surgery, she also has a limited range of motion in her neck due to the hardware from the surgery. She contends that all of these injuries and ongoing problems are permanent.

Interrogatory No. 12: Identify all your employers for the past five (5) years and the dates and nature of such employment.

ANSWER TO INTERROGATORY NO. 12:
1997 Riverview Nursing Center
1998 Riverview Nursing Center
1999 Riverview Nursing Center
2000 Canton Harbor Healthcare Center

The Plaintiff has been unable to return to work in her capacity as a Licensed Nurse Practitioner since the accident.

Interrogatory No. 13: Did you lose any time from employment as a result of the injuries sustained in this accident? If so, state precisely the dates of absence from employment, the amount of wages lost on account thereof, and the identities of the employers from whom said wages or income would have been received, and state whether or not there is a continuing wage loss or a diminished income.

ANSWER TO INTERROGATORY NO. 13: Yes. At the time of the accident, Plaintiff was earning $36.00 an hour and worked an average of 32 hours a week. To date Plaintiff has lost 202 weeks of wages, $232,352.00 in past lost wages, Plaintiff has been told that she may not be able to return to work in her capacity as an LPN. She will be making a claim for future loss of earning capacity.

Interrogatory No. 14: State the amount reported as earned income in your Income Tax Returns for each of the past five (5) years, and the district in which the Returns were filed, and attach copies of Federal and State Income Tax Returns for the past five (5) years.

ANSWER TO INTERROGATORY NO. 14: Plaintiff has not earned income since 2001. Plaintiff earned $87,000 in 1999 and $91,000 in 2000.

Interrogatory No. 15: Give an itemized statement of all expenses paid or incurred by you as a result of the accident, except for lost wages set forth in Answer to Interrogatory No. 13. Attach to your Answers copies of all bills and receipts.

ANSWER TO INTERROGATORY NO. 15:
Franklin Square Hospital $ 256.50
Lawanda Summers, M.D. $ 140.00
Rafiq K. Patel, M.D. $ 1,535.00
Keirston PT $ 8,332.00
Irfan Shafiq, M.D. $ 1,950.00
Constantine A. Misoul, M.D. $ 1,065.00
(MS DOCTORS: $ 8,409.00)
Steven A. Romener, M.D. $ 1,515.00
John Cardero, D.O. $ 3,098.92
Michele T. Cerino, M.D. $ 1,045.00
Wayne Sodano, D.C.
Harford County Ambulatory $ 3,768.00
Chesapeake Medcare Services $ 3,095.00
Avraam Karas, M.D. $ 8,875.00
Rosen-Hoffberg Rehabilitation $ 3,600.85
And Pain Management Assoc., P.A.
Upper Chesapeake Medical Center $ 780.08
Adallah J. Helou, M.D. $ 2,400.00
Good Samaritan Hospital $60,100.00
Henry A. Spindler, M.D. $ 1,475.00
Agha S. Khan, M.D. $ 640.00
Rakesh K. Mathur, M.D. $ 760.00
Advanced Radiology $ 4,101.00
Maryland General Hospital $ 1,100.00
Prescriptions (CVS) $ 43.97
TOTAL MEDICAL EXPENSES $117,985.32

Interrogatory No. 16: If you, since reaching the age of majority, have ever been convicted of any crimes, other than minor traffic violations, state the nature of the crimes, the dates of conviction, and the names and locations of the courts.

ANSWER TO INTERROGATORY NO. 16: The Plaintiff objects to this interrogatory on the grounds that it is irrelevant and the discovery of which is not likely to lead to evidence which would be admissible at the trial of this matter. Additionally, any probative value would be outweighed by the prejudicial affect. Nothwithstanding this objection, Plaintiff has not been convicted of a crime.

Interrogatory No. 17: State whether you have within your control, or have knowledge of any transcripts of testimony in any proceeding arising out of the accident. If so, state the date, the subject matter, the identity of the person recording said testimony, and the identity of the person who has present possession of each said transcript of testimony.

ANSWER TO INTERROGATORY NO. 17: Plaintiff is aware of any such transcripts of testimony.

Interrogatory No. 18: State specifically whether you received any injuries in any accident or occurrence before the accident described in the pleadings, or after it. If so, state the details, including date, place of such accidents or accident, nature of injuries sustained, and identify the parties involved, stating the identities of attending physicians and other health care providers, and dates of all examinations or treatments for such injuries.

ANSWER TO INTERROGATORY NO. 18: Plaintiffwas in a car accident in the late 1980's or early 1990's when Plaintiff injured back. I had a couple of months of physical therapy and had a complete recovery. Plaintiff sprained her ankle in 1996 and was out of work for a couple of days but had a complete recovery. Plaintiff was a passenger in a car drive by her friend, Trudy Schacor. Plaintiff saw Dr. Linder on 7/23/03, the day after the accident. Plaintiff was a little sore from the accident and had a couple of physical therapy visits and was back to baseline shortly thereafter.

Interrogatory No. 19: State whether you ever had, before the accident, complaints of pain or symptoms of disease or injury in those parts of your body which were injured in the accident. If so, state when, describe the complaints or symptoms, and identify all doctors and other health care providers who treated or provided examinations or treatments.

ANSWER TO INTERROGATORY NO. 19: See Answers to Interrogatories 9,10, and 18.

Interrogatory No. 20: State your date of birth, social security number, and your height and weight, both now and at the time of the accident. If a married woman, state your full maiden name.

ANSWER TO INTERROGATORY NO. 20: DOB: 1/20/67; SSN: 215-88-8720; Height: 5' 7" and Weight: 163 lbs. now; Height: 5' 7" and Weight: 175 lbs. at the time of the accident. Schalizki, Newon and Haggerty are other last names I have had.

Interrogatory No. 21: State the itinerary of your vehicle for the four (4) hours prior to the accident, including the time and place of the beginning of the trip, the time and duration of each stop, the place of destination, and the expected time of arrival.

ANSWER TO INTERROGATORY NO. 21: At the time of the accident, Plaintiff was on her way to take her son to see his doctor and was coming from home. Plaintiff was expected to be at the doctor's office around 4:30 p.m. Plaintiff was not running late at the time of the accident.

Interrogatory No. 22: State whether you consumed any alcoholic beverages, medications, or drugs within eight (8) hours prior to the accident, places where such alcoholic beverages, medications, or drugs were obtained, and the nature and amount thereof.

ANSWER TO INTERROGATORY NO. 22: Within (8) hours prior to the accident I did not consume any alcoholic beverages. At the time of the accident, I was not taking any medication.

Interrogatory No. 23: State what part of your vehicle was damaged, and if it was repaired, the identity of the person who performed such repairs, the dates of such work, and the cost thereof. If the vehicle is unrepaired, state the address and the hours at which time it may be seen.

ANSWER TO INTERROGATORY NO. 23: The driver's side corner of Plaintiff's vehicle was damaged. A repair estimate was performed. It cost approximately $8,000.00 to repair the vehicle. See repair records already produced.

Interrogatory No. 24: Outline in detail the work schedule, physical and other activities for the Plaintiff(s), for the 24-hour period immediately before the accident.

ANSWER TO INTERROGATORY NO. 24: Within the 24 hours prior to the accident Plaintiff was at work the day of the accident and the day before.

Plaintiff does not recall doing anything unusual the night before the accident.

Interrogatory No. 25: If any person, firm, corporation, or governmental agency has a subrogated interest in any item of damage you have claimed in this action, identify the firm, person, corporation, or governmental agency, and the amount its interest.

ANSWER TO INTERROGATORY NO. 25: Objection as to relevance.

Interrogatory No. 26: Identify all persons not heretofore named in your answers to these Interrogatories who have personal knowledge of facts concerning the happening of the accident or of your injuries, losses, and damages. Specify in which category each such person has knowledge.

ANSWER TO INTERROGATORY NO. 26: All individuals identified within these answers to interrogatories have personal knowledge of the facts in this case.

Interrogatory No. 27: As to any document, object, or other item produced by you in this case which has been altered prior to or as a part of the production process, state its identity with sufficient specificity to identify it, the nature of each alteration (i.e., the material or condition prior to alteration and the material or condition after the alteration), the date of each alteration, the name and address of each person who made each alteration and the reason or purpose of each alteration.

ANSWER TO INTERROGATORY NO. 27: Not to Plaintiff's knowledge. Gertrude Jones, Norman Mailer, and William Phillips are personal friends who can testify as to her injuries, pain, and suffering.

OATH

I do solemnly declare and affirm under the penalties of perjury that the foregoing Answers to Interrogatories are true and correct to the best of my knowledge, information and belief.

ANNE POWERS

Certificate of Service

I hereby certify that a copy of the foregoing has been sent via U.S. Mail, first-class, postage prepaid, on the 25th day of July, 2005, to:

Neal S. Wadler, Esq.
Nationwide Insurance
8600 LaSalle Road
The Oxford Building, Suite 620
Towson, MD 21286-5955

Respectfully submitted,
MILLER & ZOIS, LLC

Ronald V. Miller, Jr.
Laura G. Zois

1 South St, #2450
Baltimore, MD 21202

(410)779-4600
(410)760-8922 (fax)
Attorneys for the Plaintiff

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