INTERROGATORIES

TO:  Defendant

FROM:  Counsel for Plaintiff

            The following Interrogatories are served upon you pursuant to the Maryland Rules. They are to be answered by you fully, in writing, on oath, and within 30 days of their receipt, unless by agreement or Court order such time is extended:

            (a) These Interrogatories are continuing in character, so as to require you to file supplemental answers at any time that you should obtain further or different information.

            (b) Where the name or identity of a person is requested, please state the full name, home address and business address, if known.

            (c) Unless otherwise indicated these Interrogatories refer to the time, place and circumstances of the occurrence mentioned or complained of in the pleadings.

            (d) Where knowledge of 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 a corporate Defendant, state the name, address and title of the person supplying the information and making the affidavit, together with the source of his information.

            (e) The pronoun “you” refers to the party to whom these Interrogatories are addressed and the person mentioned in clause (d).

DEFINITIONS

            (a) As used in this Notice, the term “document” means, without limitation, the following items, whether printed or recorded or reproduced by any other mechanical process, or written or produced by hand: agreements, communications, state and federal governmental hearings and reports, correspondence, telegrams, memoranda, summaries or records of telephone conversations, summaries or records of personal conversations or interviews, diaries, graphs, reports, notebooks, note charts, plans, drawings, sketches, maps, summaries or records of meetings or conferences, summaries or reports of investigations or negotiations, opinions or reports of consultants, radiographs, photographs, motion picture film, brochures, pamphlets, advertisements, circulars, press releases, drafts, letters, any marginal comments appearing on any document, and all other writings, all originals and all copies not identical to the original or to each other; all drafts; two writings of any kind; tapes, computer discs, CD Rom, CD-R, CD-RW, DVD, microfilm, microfiche, raster bitmaps, magneto optical (MO) disks, electronic images and associated indexing data, Write Once Read Many (WORM) laser disks; or any other form of photographically or electronically, digitally, magnetically impulsed, or otherwise recorded or represented information, image or document storage, including, but not limited to word processor document resource information (e.g. MS Word, Corel WordPerfect “properties” tabs) drafts and redlined versions of documents, compound documents (e.g. documents where the image is one file and the text is in another); e-mail and voice-mail archives; e-mail and voice-mail messages and backups; databases; document management databases; Internet service provider’s records, including user account information and identification of firewalls, caches and cookies; network router traffic indicia; world wide web pages, including but not limited to HTML, XML, SGML, XGML, VRML, Adobe Acrobat, Corel Envoy, MIF, RTF, EPS, prepress formats.

            If the Defendant considers any document called for in these Interrogatories to be privileged from production, then the Defendant must include in the answers to these Interrogatories a list of documents withheld from production, identifying each document by date, addressee(s), author, title, and subject matter. In addition, the Defendant should identify those persons who have seen the document or who were sent copies. Finally, the Defendant should state the ground(s) upon which each such document is considered privileged.

            (b) “Identify” or “identification,” when used in reference to an individual person, means to state his full name, his present address, his present business address, and his present or last known position and business affiliation.

            (c) “Describe” or “description,” (i) when used in reference to persons or members of a class, means to identify each individual person or member of a class; and (ii) when used in reference to a document, means to state the following as to each document:

(1) the nature and contents thereof;

(2) the date thereof;

(3) the date the document was executed if different from the date it bears;

(4) the name, address, and position of the author or signer thereof;

(5) the name, address, and position of the addressee, if any;

(6) the present location thereof and the name, present address, and position of the person or persons having present custody thereof; and

(7) whether the document has been destroyed and, if so, with regard to such destruction,

(i) the date thereof;

(ii) the reason therefore; and

(iii) the identity of the person or persons who destroyed the document.

(d) “Occurrence” means the vehicular collision involving Plaintiff described with particularity in the Complaint.

 

 

 

INTERROGATORIES

  1. State your full name, current address, date of birth, social security number and work address and list all the positions you held in the past and your current position.
  2. Identify any individual that you are aware that has personal knowledge of the facts and circumstances of this case, including eyewitnesses and any individuals who arrived on the scene within two hours after the occurrence.
  3. If anyone investigated this matter for you, including medical experts, private investigators or insurance adjusters and state their name(s) and address(es), and state whether such investigation was reduced to writing. If said investigator obtained any signed statements or recorded statements, identify the person who gave the statement and attach to your Answers a copy of any said statement.
  4. If you know of the existence of any pictures, photographs, plats, visual recorded images, diagrams or objects relative to the occurrence, the Plaintiff’s physical condition, or the scene of the occurrence, identify the substance of such recording and the present custodian of each such item.
  5. Please identify the owner and the driver of the vehicle involved in the accident with the Plaintiff and under what specific circumstances the driver of the vehicle was permitted to operate the owner’s vehicle on the date of the accident.
  6. Please state the relationship of the driver to the owner of the vehicle which was involved in the accident with the Plaintiff.
  7. Please state where Defendant Jane Doe was heading to and the time of the accident and where Defendant Doe  was coming from and their expected time of arrival.
  8. Please list all accidents involving Defendant Doe , within the past five (5) years. For each such accident, please include the name and address of any driver of 's vehicle involved, the name and address of any other driver involved, the court and case number of any action that resulted, and the result of each such action.
  9. Please state the extent of Defendant Doe  knowledge of Defendant Doe  driving history.
  10. Please list all insurance agreements you have regarding the vehicle operated by Defendant Doe  at the of the collision with the Plaintiff, including the name of the insurance company, the name of the policy owner, 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.
  11. State whether Defendant Doe  was acting as the agent, servant or employee of Defendant Doe  at the time of the occurrence.
  12. Identify the property damage done to each vehicle as a result of the accident and which parts of those vehicles were damaged in the occurrence complained of, the name and address of the person or entity who repaired each vehicle, and the date and cost of repairs. If the vehicles have not been repaired, state the present location of said vehicles, the days of the week, the time of day, and the places they may currently be seen and identify any photographs of the vehicles involved in the collision.
  13. Please state with specificity exactly how this accident took place and include in your answer, the date of the accident, the time of the accident, the location of the accident, where you vehicle was just prior to the accident, where the Plaintiff’s vehicle was just prior to the accident, how far away the Plaintiff’s vehicle was just prior to the impact, the speed of your vehicle just before the accident, the speed of the Plaintiff’s vehicle just before the accident, the speed of the vehicles upon impact, and the exact locations in relation to the roadway upon impact, if this was a chain reaction accident, identify the sequence of the impacts between the vehicles.
  14. Do you admit that you caused the accident and that the Plaintiff was injured in the collision?