Sample Truck Accident Interrogatories Directed to Truck Driver

IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND

Patrick Jackson- Plaintiff

v

Brody Transportation - Defendant

CASE NO.: 06-C-00-1234

PLAINTIFF'S INTERROGATORIES TO DEFENDANT TRUCK DRIVER

TO: Defendant Truck Driver
BY: Plaintiff

Plaintiff, by and through his attorneys, Laura G. Zois and Miller & Zois, LLC, requests that Defendant (hereinafter "Defendant Truck Driver") answer the following Interrogatories fully, under oath and in accordance with the Maryland Rules of Civil Procedure, Rule 2-421, subject to the instructions set forth below:

Instructions
  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 attorneys. 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.
Interrogatories
  1. Identification: State your full name, home addresses for the past ten years, your employer for the last 10 years, your current work address, date of birth and social security number.
  2. Insurance Coverage: Identify all insurance carriers or self-insured funds, by name, address, policy numbers and policy limits, for any insurance policy or fund which may provide coverage for any judgment entered against you related to this occurrence.  If you are aware of any indemnification or contribution agreements between any of the Defendants, please identify those agreements. 
  3. Negligence: If you contend that any other entity or person, including any of the parties or the Plaintiff, was responsible for the automobile collision and Plaintiff’s injuries, identify such person(s) or entities, and give a concise statement of the facts upon which you rely in support of your contention.
  4. Expert Witnesses: State the name, business address, home address, telephone number, and area of expertise of all experts whom you propose to call as witnesses at trial or whose opinions you intend to utilize at the trial of this matter.  For each expert state the amount of compensation paid, the subject matter on which the expert is expected to testify, the expert's opinions and the factual basis for their opinions. 
  5. Documents:  Identify any documents and recordings including, but not limited to, pictures, photographs, PowerPoint presentations for use at trial, demonstrative exhibits, computer generated exhibits, electronically stored data, visual aids, overlays, employment records, plats, visual recorded images, audio recordings, cassette tapes, transcripts of testimony, diagrams and objects relative to the occurrence, the scene of the occurrence, Plaintiff’s physical condition or statements made by any party or witness.  Identify the substance of the item, the date obtained, what is depicted within the item, and the name and address of the present custodian of each item. 
  6. Statements: If you, your insurance carrier, private investigator, or any other person or entity is in possession of any written, oral or recorded statements by any party or person with personal knowledge relative to the occurrence, indicate the date and time each statement was obtained, the name and address of each person who provided the statement, the contents of the statement, and the name and address of the current custodian of the statement.
  7. Plaintiff’s Conduct/Statements: Describe any conduct, comment, conversation, statement, or report made by this Plaintiffs or any other person, at the scene of the occurrence or at any time, concerning fault for the occurrence or facts relevant to any issue in this case.  Include in your answer where the conduct, comment, conversation, or statement took place, and in whose presence it was made/observed, as well as the name of the author of such statement, the present custodian of the statement and the address for the custodian.
  8. Past Criminal Convictions: Since your eighteenth birthday, when you were represented by an attorney or waived the right to be represented by an attorney, state whether you have been found guilty of, or plead guilty to, any crimes other than minor traffic violations (i.e., those traffic offenses without the potential penalty of incarceration) and, if so, state the nature of the offense, the date of each conviction, and the full name of the court where each conviction was entered.
  9. Other Proceedings: If you are aware of any other case or proceeding involving the incident identified in Plaintiffs Complaint including, but not limited to, civil, criminal or administrative actions, identify the case or action by tribunal, case number, docket number or citation number, the date of any hearing, and indicate any pleas in the case(s) and the disposition of the matter(s).
  10. Property Damage: Identify the property damage each vehicle involved in the accident sustained as a result of the accident, any repair estimates or photographs, and the name, address, and title of any claim adjuster or claim representative who inspected the vehicles, the name and address of the person or entity that repaired each vehicle, and the date and cost of repairs.  If the vehicles have not been repaired, state the present location of said vehicles and the days of the week, times of day and locations where they may be seen.
  11. Impairment: State whether you, the driver of your vehicle, or any witness to the incident consumed any alcoholic beverages or drugs, whether prescription, over-the-counter or illicit, within twenty-four (24) hours prior to the occurrence.  If the answer is in the affirmative, identify the individual, state the name of the substance, where and when it was obtained and consumed, and the amount thereof.
  12. People with Personal Knowledge: Identify any person who has personal knowledge of the facts and circumstances of this case and any person you intend to call as a witness at the trial, including investigators or any individual who was an eyewitness, or claims to be an eyewitness, regarding all or part of the occurrence including, but not limited to, passengers in your vehicle, passengers in Plaintiffs vehicle, and persons who arrived at the scene after the accident.  State in your answer the name, address, current telephone number, substance of their knowledge, expected testimony and any lay opinions.
  13. Facts of the Occurrence: Give a detailed statement of how you contend the occurrence took place, including where you were traveling from and traveling to, any stops made along the way, the date, time, location of the accident, the direction of each vehicle before the accident, the speed of each vehicle before the accident, the path of each vehicle leading up to the accident, the speed of the vehicles upon impact, the resting place of each of the vehicles, and the status of any traffic control devices at the location of the accident.  If this was a chain reaction accident, identify the sequence of the impacts between the vehicles. 
  14. Driver/Owner: State whether you were the driver and/or owner of the vehicle involved in the occurrence on the date, time and location as outlined in Plaintiffs Complaint.  If you were not the driver, then state who you claim was driving the vehicle that collided with the Plaintiffs vehicle, including the driver’s name, address, telephone number and the basis for this knowledge.  If you were not the owner, then state the name and address of the owner, whether you had the permission of the owner to operate the vehicle, whether there were any restrictions placed on your use of the vehicle, and the purpose for which you were operating the vehicle.
  15. Agency: If you were employed at the time of the occurrence, as indicated in Plaintiffs Complaint, and working within the scope of that employment when the occurrence took place, identify your employer and the nature of the work you were performing.
  16. Post Occurrence Medical Treatment: Subsequent to the collision mentioned in Plaintiffs Complaint, were you tested, examined, or treated by any medical facility or medical personnel, including but not limited to drug testing by your employer? If your answer is in the affirmative, state:
    1. the name and address of the medical care provider or facility;
    2. the nature of your injuries;
    3. the nature of your examination, including x-rays, MRIs, blood tests, and the results thereof;
    4. the duration of your stay in the hospital or medical care facility; and
    5. whether you missed any time from your employment as a result of the injuries you received in the occurrence and, if so, a statement of the time missed.
  17. If any blood, breath or urine tests were done, state:
    1. each person from whom a blood sample or breath sample was taken;
    2. the name, address and occupation of the person who drew each sample;
    3. the name, address and occupation of the person who conducted the tests on each sample;
    4. the time and date on which each sample was drawn;
    5. the time and date on which the tests were conducted; and
    6. the results of the tests.
  18. Other Civil or Criminal Matters: Please list every civil, criminal and administrative matter wherein you were a party to include the complete caption, nature of the case, the case number, state, city, county and state where action was located and name and address of all parties and their attorneys.
  19. Medical Treatment Contention Interrogatory:  If you contend any of the medical treatment received by the Plaintiff was unreasonable or unnecessary, or any of the bills for the medical treatment were unreasonable or excessive, please state the factual basis for this contention and identify each specific date of treatment and each medical bill that you claim was unreasonable/unnecessary/excessive; and identify all witnesses who will provide testimony on this issue to include any expert witnesses and their opinions.
  20. Injuries: Contention Interrogatory:  If you contend that the injuries and/or disabilities now complained of by the Plaintiff was the result of prior or subsequent injuries or illnesses, or not caused by the occurrence referred to in Plaintiffs Complaint, give a detailed statement of the facts upon which you rely, identify the names of all experts who have provided opinions regarding such contention.
  21. Prior Medical History: Indicate any injury, disability, illness, medical, and/or psychological condition which you suffered on the date of the occurrence (prior to and immediately following the collision) and the medications (type and quantity) you were prescribed and taking (this includes, but is not limited to, any blindness, corrective lenses to improve eyesight, loss or reduction of hearing, use of prosthetic devices, wearing any type of body/arm/leg cast, an inability to speak, color blindness, and dyslexia); if you contend any of these conditions prevented you from operating your vehicle in a safe and prudent manner on the date of the automobile collision and caused you to collide with the Plaintiffs vehicle then detail all facts to support this contention, including the name, title and address of any proposed witness, and the details of the expected testimony of each witness you intend to call in support of this contention.
  22. Lost Wages Contention Interrogatory: If you contend the Plaintiff was not disabled from employment as claimed due to injuries she sustained in the occurrence, state the factual basis for this contention, and detail any opinions upon which you rely in support of your contention.
  23. Relationships With Others: Please state the name, current address, phone number, and relationship to you of:
    1. a. every person in the vehicle with you at time of the occurrence complained of;
    2. b. every person, company, corporation or entity that may claim total or partial ownership in the vehicle in which you were operating at the time of the occurrence; and
    3. c. any and all individuals listed on the insurance policy covering the vehicle in which you were operating at the time of the occurrence.
  24. Lay Opinion: State the content of any lay opinion that you are aware of or intend to elicit from any person at trial.  Please indicate the name and address of the person with such opinion and the date and time said opinion was formed.

MILLER & ZOIS, LLC

Laura G. Zois
1 South St, #2450
Baltimore, MD 21202
(410) 779-4600
(410) 760-8922 ( facsimile)
Attorney for Plaintiff

MILLER & ZOIS, LLC

Ronald V. Miller, Jr.
Laura G. Zois
1 South St, #2450
Baltimore, MD 21202
(410) 779-4600
(410) 760-8922 ( facsimile)
Attorney for Plaintiff

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