FIRST SET OF INTERROGATORIES TO INSURANCE COMPANY
TO: GEICO, Defendant
FROM: Plaintiff
The following Interrogatories are propounded pursuant to the Maryland Rules of Procedure and are to be answered fully and under oath:
a. These Interrogatories are continuing in character, so as to require you to file supplementary answers if you obtain further or different information before trial.
b. Where the name or identity of a person is requested, please state full name, home address, and also business address, if known, as well as the home and business telephone number.
c. Unless otherwise indicated, these Interrogatories refer to the time, place, and circumstances of the auto accident mentioned or complained of in the pleadings.
d. 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 a corporation or other legal entity, state the name, address, and title of the person supplying the information, and making the affidavit, and the source of his information.
e. Said Interrogatories shall include the following definitions:
i. Any request to identify any record, documents, or writing shall include identification as to: (a) the date the same was dated or otherwise prepared; (b) the name, address, and title of the person preparing same; (c) the name, address, and title of the person for and to whom the same was prepared and addressed; (d) the name, address, and title of all persons to whom copies of the same were furnished or otherwise forwarded; (e) the title and other identifying designation given the same; (f) the subject matter and content of the same; and (g) the name, address, and location and title of the person having possession.
ii. The pronoun "you" refers to the party to whom these Interrogatories are addressed, its agents, servants, employees, representatives, officers, or anyone acting for or on behalf of that party.
1. State the name and address of the person answering these
Interrogatories, your title, your affiliation with the Defendant,
and the length of time with the Defendant in that position.
2. State whether there was a contract of insurance between the
insurance company and the Plaintiff to provide uninsured/underinsured
motorist benefits.
3. Name the eyewitnesses you are aware of that witnessed all or
part of the auto accident, and state the location of each such
eyewitness at the time of the auto accident.
4. Name all persons and/or personnel who were at or near the scene,
or arrived at the scene within two hours after the auto accident.
5. If anyone investigated this matter for you, 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.
6. If you contend that the Plaintiff in this action was negligent
in causing the auto accident, state the reason(s) you make this
contention. Include in your answer where and from whom you obtained
the information to make this contention.
7. State whether you have within your possession or control photographs,
plats or diagrams of the scene, videotapes, or objects connected
with said auto accident; and if so, identify each such object,
the date produced or obtained, and the present custodian thereof.
8. State the manner in which you say the incident complained of
occurred, giving the various speeds, positions, directions, and
locations of all vehicles involved in the said accident.
9. State whether you have within your possession or control, or
have knowledge of, any transcripts of testimony, in any proceedings
arising out of the auto accident. If so, state the date, the subject
matter, the name and address of the person who has present possession
of each said transcript of testimony.
10. Do you know of any statement, conversation, comment, or report
made by this Plaintiff at the time of the auto accident or following
the auto accident, concerning the auto accident or facts relevant
to any issue in this case? If your answer is "yes,"
state the content of such statement, conversation, comment, or
report, the place where it took place, and in whose presence it
was made.
11. State the name and specialty of all experts whom you propose
to call as witnesses at trial, and for each expert state the subject
matter on which the expert is expected to testify, the substance
of the findings and opinions to which the expert is expected to
testify and attach to your Answers copies of all written reports
of each such expert.
12. What investigation have you done to determine whether the
driver or owner of the vehicle that was involved in the auto accident
with the Plaintiff was insured with liability insurance at the
time of the auto accident? Include in your response, the results
of that investigation and by whom it was conducted.
13. Were there any charges placed against the uninsured driver
or owner of the vehicle involved in the auto accident with the
Plaintiff as a result of this auto accident and if so, did they
plead guilty or were they found guilty of any violation arising
from the auto accident? If so, state the violation they were charged
with, and where and when they pled or were found guilty.
14. State the name of any insurance company that might be liable
to satisfy all or part of any judgment that might be entered against
the driver or owner of the vehicle involved in the auto accident
with the Plaintiff in this case, and for each company named, state
the limits of coverage.
15. State who owned the various vehicles involved in the auto
accident and which parts of those vehicles were damaged in the
auto accident 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.
16. If you contend that the Plaintiff suffered from a pre-existing
condition please state all facts upon which you rely to support
your contention.
17. If you contend that the Plaintiff aggravated a preexisting
condition please state all facts upon which you rely to support
your contention.
18. If you contend that the Plaintiff’s injuries were not
sustained in the auto accident of November 15, 2007, please state
all facts upon which you rely upon to support your contention.
19. Please identify any medical expert that you have consulted
with and who has rendered opinions prior to answering these interrogatories
and whose opinions you have relied upon in denying this claim.
Respectfully
submitted,
MILLER
& ZOIS, LLC.
Ronald
V. Miller, Jr.
Laura
G. Zois
Empire
Towers, Suite 615
7310
Ritchie Highway
Glen
Burnie, Maryland 21061
(410)553-6000
(410)760-8922
(Fax)
Attorneys
for the Plaintiff
See also More Interrogatories(sample interrogatories in personal injury cases)
See also Arbitration
Clauses and Maryland Car Insurance Contracts
See also Problems with Maryland Pay to Play Statute (practical concerns about the timing of the tender of the insurance policy under Maryland Insurance Code Ann. § 19-511)
See also Schuler
v. Erie Insurance Exchange (new subrogation waiver law)
See also State
Farm Mutual Auto Insurance Co. v. Crisfulli
See also Uninsured
Motorist Interrogatories (aggressive sample interrogatories)
See also Sample Uninsured Motorist Release (example UM release)
See also Summary of Uninsured Motorist Trial in Baltimore (story of a trial)
See also Sample
Uninsured Motorist District Court Complaint (example smaller claims complaint)
See also Sample
Uninsured Motorist Circuit Court Complaint (sample lawsuit)
See also Maryland
Uninsured Motorist Statute (the Maryland law)
See also Breach of
Contract (the foundation of any UM claim)
See also Contact us or call
1-800-553-8082
