Interrogatory No. 1: State your full name, address, date of birth, marital status and Social Security Number.
Interrogatory No. 2: State the full name and last known address of every person known to you or to your attorneys who was an eyewitness to all or any part of the occurrence referred to in the Complaint and state their location at the time.
Interrogatory No. 3: State the full name and last known address of every person known to you or your attorneys who arrived at the scene of the occurrence within two (2) hours of the happening of the occurrence.
Interrogatory No. 4: State the full name and last known address of every person known to you who has any personal knowledge of this car accident. .
Interrogatory No. 5: Describe in detail the facts as to how you contend that the occurrence took place, including a description of the respective speeds, directions, and movement of any vehicles involved, just before, during, and after the occurrence.
Interrogatory No. 6: Give a detailed statement of all facts upon which you rely to show that the Defendant was negligent.
Interrogatory No. 7: State the names and addresses of all persons known to you or to your attorneys who have given signed or recorded statements relative to all or any part of the occurrence and state the date the signed or recorded statement was given, to whom it was given and the present custodian of each such signed or recorded statement. Attach hereto a copy of all signed statements made by the party propounding these Interrogatories.
Interrogatory No. 8: If you know of the existence of any pictures, diagrams or objects (real evidence) 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. 9: If you contend that any document, letter, report, writing or any written instrument of any type or description is relevant to any issue in this case, identify each such written instrument, including the date and identity of the person preparing or signing such written instrument.
Interrogatory No. 10: State whether 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 Court wherein each conviction occurred.
Interrogatory No. 11: If you consumed any alcoholic beverages of any type, or any sedative, tranquilizer or other drug, medicine or pill during the 48 hours immediately preceding the incident referred to in the Complaint, state the nature, amount and type of item consumed, the amount of time over which each was consumed and the names and addresses of any and all persons who have any knowledge as to the consumption of these items.
Interrogatory No. 12: State whether you have within your control, or have knowledge of any transcripts of testimony in any proceeding arising out of the occurrence. If so, state the date, the subject matter, the name and business address of the person recording said testimony, and the name and address of the person who has present possession of each such transcript of testimony.
Interrogatory No. 13: If you contend that the party propounding these Interrogatories at any time made an admission against interest with respect to any issue involved in this litigation, state the date and place and in whose presence the admission against interest was made and the nature thereof.
Interrogatory No. 14: Name all experts whom you propose to call as witnesses and attach copies of all written reports made to you by any such experts; and if no such report has been prepared, state in detail the substance of the expert’s testimony, and in any event, state the expert’s area of expertise.
Interrogatory No. 15: State with precision the nature and location of bodily injuries suffered by you; and if you have any complaints on account of injuries received in the occurrence, state in detail the nature of such present complaints.
Interrogatory No. 16: State which of your injuries, if any, you contend are permanent.
Interrogatory No. 17: Name all hospitals and physicians or any other persons or institutions who have examined or treated you as a result of the occurrence for which this suit has been brought and state the dates and nature of such examinations and treatments.
Interrogatory No. 18: If you have ever suffered any injuries in any accident, 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 hospitals, physicians, surgeons, osteopaths, chiropractors or 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 persons or organization paying such compensation and the amount thereof.
Interrogatory No. 19: If you have ever had any serious illness, sickness, disease, or surgical operations, either prior to subsequent to the occurrence referred to in the Complaint, state the date, a detailed description of your symptoms, the names and addresses of all physicians, surgeons, osteopaths, chiropractors, medical practitioners and hospitals rendering treatment (including therein insurance policies under which payment for treatment was sought and patient identifying insurance numbers), the date your condition became stationary and a description of your condition at that time.
Interrogatory No. 20: 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, and give 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. 21: If you were an insured (or beneficiary) under any policy of insurance under which you received benefits or reimbursement for medical expenses or any other losses resulting from the occurrence referred to in the Complaint, state the name and address of the company paying the benefits and whether the company required you to assign to it any rights of recovery you may have against others.
Interrogatory No. 22: With respect to each of the past five (5) years, state your yearly gross income and yearly net income as reported on your Federal Income Tax Returns and state the name and address of the person, firm or corporation having custody of any papers pertaining to your income.
Interrogatory No. 23: 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, a detailed description of the work performed for each employment and your average weekly wages or earnings from each employment.
Interrogatory No. 24: If you have lost any time from your employment, business or occupation since the car accident, state the cause of such loss of time, the date of such loss of time and the amount of wages or income lost.
Interrogatory No. 25: Itemize the expenses made or incurred by you in the past or that you expect to incur in the future as a result of the occurrence.
Interrogatory No. 26: If any of the persons named in response to the preceding Interrogatories are known or related to you, or to each other, state the nature of such acquaintanceship or relationship.
Interrogatory No. 27: Name any person, not heretofore mentioned, having personal knowledge of facts material to this case.