Sample Interrogatories

You will find below model interrogatories in many different types of personal injury cases. For more sample discovery, pleadings, depositions, motions and trial materials, visit the Personal Injury Lawyer Help Center. If you are a lawyer with an accident, malpractice or product defect case in Maryland that you may wish to refer, visit our lawyer referral page.

Sample Interrogatories Propounded on DefendantInterrogatories

Sample Interrogatories Propounded on Plaintiffs by Insurance Company Lawyers

Sample Interrogatory Answers - how to answer interrogatories

      As most people reading this know, interrogatories are written questions requiring the responding party to provide written answers under oath. In most jurisdictions, including Maryland and under the Federal Rules of Civil Procedure, parties in a personal injury case may serve thirty interrogatories to each other and typically have thirty days to respond. Because the number of interrogatories permitted is restricted to thirty, interrogatories should be carefully drafted to request only information not readily available from other sources that cannot be disposed of with, for example, requests for admission. In determining the number of interrogatories propounded, subparts are counted separately. So asking an interrogatory with several questions does not help keep the number down, no matter how they are arranged or numbered. If an interrogatory has five related subparts, it will be counted as five interrogatories. Be wary, however, of the overzealous defendant's personal injury lawyer deeming a question asking about, for example, communications of a particular type as multiple interrogatories because it requests time, place, persons present, etc. This type of request really should be considered one interrogatory.
      In 1994, Maryland Rule 2-421 was amended allow a party to serve more than a single set of interrogatories. But the total number of interrogatories cannot exceed thirty. Accordingly, our attorneys suggest serving more than one set of interrogatories, first serving initial interrogatories as well as later ''clean-up'' interrogatories so long as the total number of questions does not exceed 30. In the sample interrogatories above, the first set listed assumes that all 30 interrogatories are asked at one time. The next three sample sets of interrogatories - using the preferred Plaintiff's personal injury attorney method - are sent throughout the course of discovery. Incredibly, last year once of our lawyers in a truck accident case in Baltimore City refused to answer discovery because the attorney thought three sets of requests for admission and interrogatories are just too much. Unfortunately, I do not think this attorney has ever read Maryland Rule 2-421 or Maryland Rule 2-424. Fortunately, our lawyers are sure that the judge that hears the motion to compel has read these rules.

      When using multiple sets of interrogatories, another tactic that leads to quality information about the case the defendant's attorney intends to present at trial is using alternative interrogatories. These interrogatories are used in conjunction with requests for admission. If a party denies a request for admission that goes to a critical component of Plaintiff's personal injury case, a alternative interrogatory asks the defendant's lawyer to set forth all facts and evidence upon which the defendant intends to rely upon at trial to support the defense lawyer's denial.

     This rule does not direct how the interrogatory is asked. It can be either in the form of a question (usually contention interrogatories) or interrogatories can direct the answering party to supply specific information that is described.

      Why are interrogatories so important to medical malpractice and accident lawyers? Interrogatories are frequently the best line of discovery for the lawyer to know the factual basis on which the defendant's lawyer intends to defend the case and the areas the plaintiff's lawyer needs to explore further with other discovery mechanisms. Deposition questions and requests for admissions of fact, for example, may be framed using information obtained in answers to interrogatories.

      We say "doggedly pursued" because Maryland lawyers defending auto accident, truck accident and medical malpractice cases have mastered the art of the objection. Many Maryland attorneys representing the defendants and their insurance companies often refuse to answer Plaintiff's interrogatories in personal injury auto accident cases. These Maryland lawyers will look for creative ways to circumvent answering discovery. These lawyers are comforted by the fact that few plaintiffs' lawyers in Maryland personal injury cases actually hold these defense lawyers feet to the fire and make them answer in spite of the lawyer's objections.

     The frivolous objections that these Maryland lawyers - particularly truck accident lawyers for whatever reason -make come in many shapes and sizes. The most classic lawyer objection is that the interrogatory asked is objectionable under Maryland law on the grounds that it is "vague, burdensome, over broad, and not reasonably calculated to lead to admissible evidence." Maryland defense lawyers in personal injury cases use this objection to the simplest of questions. These Maryland lawyers also object to interrogatories because a specific word is not defined (no matter what the word is, right down to question what the definition of "is" is). No matter what the objection, the key is to object quickly and press the defendant's lawyer with a motion to compel if necessary. The process adds layers of time and expense, because a motion needs to be drafted and typically the Maryland judge will require the lawyers to attend a hearing on the motion. But the effort is worth getting proper and complete answers to the plaintiff's interrogatories.

 

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