Model Interrogatories

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Background Information on You

Please state your full name and present address; your date and place of birth; marital status, and your social security number.

State the name and address of each of your employers, including self-employment, from ten (10) years preceding the incident in question through the present, stating the respective dates of such employment and providing a description of your duties at each job, including such particulars as work schedules, nature of the work, and whether the work involved manual labor, long periods of standing or long periods of sitting.

Please state the names and relationships of any person living with you at your current address and indicate whether said person(s) resided with you on the date you were injured.

Have you ever been convicted of treason, murder, rape, arson, burglary, robbery, kidnaping, forgery, perjury, or any other crime involving dishonesty or false statement? If so, please state the description of each crime; the date that You were convicted; the caption and cause number of the proceeding in which You were convicted; and the name and address of each court involved.

Have you ever filed bankruptcy? If so, please state the following: (a) date on which you filed; (b) the Chapter under which you filed; (c) the name(s) you used in filing; (d) the court in which You filed; and (e) the caption and cause number of the proceeding.

Information About the Incident

Please give a detailed description of the alleged accident, including such particulars as the date, time, street address of the location where the alleged incident happened and weather conditions at the time of the alleged incident.

Please describe your actions immediately before, during and after the incident which forms the basis for this lawsuit.

If any photographs were taken of the scene of the alleged occurrence or the persons involved, please state the date or dates on which such photographs were taken, the subjects thereof and who presently has custody of any such photographs.

Information About Your Injuries

Please describe any and all accidents, illnesses and/or personal injuries, and any and all infirmities or disabilities which you have had in the fifteen (15) years prior to the accident sued upon herein, and describe all medical treatments therefor, including the name and address of every doctor or medical practitioner examining or treating you; the name and address of every hospital or medical institution where you have been treated, examined or cared for; the dates of all such examinations or treatments; and the nature of all such examinations or treatments.

Please state the nature and extent of any injury and/or other disability you have suffered with regards to the parts of your body that were injured in this incident, and describe all medical treatment or care you have received therefor, including the name and address of every doctor or medical practitioner examining or treating you, and the dates of all such examinations or treatment.

State the nature and extent of every injury you claim to have been a result of this incident, and describe all medical treatment or care you have received therefor, including the name and address of every doctor or medical practitioner examining or treating you; the name and address of every hospital or medical institution where you have been treated, examined or cared for; the dates of all such examinations or treatments; and the nature of all such examinations or treatments.

Please describe any and all accident and/or personal injuries, and any and all infirmities and/or disabilities which you have had since the accident sued upon herein; and describe all medical treatment received therefor, including the name and address of every doctor or medical practitioner examining or treating you; the name and address of every hospital or medical institution where you have been treated, examined or cared for; the dates of all such examinations or treatment, and the nature of all such examinations or treatments.

Please state the name and address of your family physician from 1983 to the present time.

Please state specifically, in itemized form, each and every expense incurred by you or on your behalf for the medical treatment of the injuries alleged in your complaint.

If you have ever been assigned a disability or permanent impairment rating prior to or as a result of the injuries in question, please state the extent of disability or impairment assigned, the date such opinion was rendered, and the name and address of the physician assigning it.

Describe each and every way in which you claim to have been damaged by the incident in question, including activities, if any, which you claim you can no longer perform.

List each separate injury or condition you allege to have sustained as a result of this occurrence and for each such injury state the following: the nature of the injury; the location of the injury; the duration of the injury if resolved; and the estimated duration of the injury if still present.

If you had any pre-existing condition at the time of this occurrence that you allege was affected by the occurrence or affected the extent of duration of the injuries you allege to have received, state the following: the pre-existing condition; its duration before this occurrence; its effect upon your injuries or the effect of the occurrence upon the condition; and the name and address of each practitioner or institution where you had been examined or treated for this condition before this occurrence.

If you were reimbursed for all or any part of your medical expenses or if all or any part of your medical expenses were paid directly by a third party, whether an individual or organization, state the following: the name and address of the third party; the expenses paid or reimbursed by the third party; and whether the third party has or claims a subrogation right or lien on any settlement or judgment as a result of such payments.

Information About Other Damages to You

State in itemized form the amounts, dates incurred, and persons or businesses with whom all non-medical expenses which were incurred by you or on your behalf as an alleged result of the injuries sued upon in this case.

If you are making a claim for lost wages, please state the amount of the wage loss claim and the means used to calculate the loss.

Information About Witnesses

If you had any conversations with the Defendant, or any of their servants, agents or employees following the incident in question, please describe the substance of said conversations and the person or persons with whom you had such conversations.

Please state the full name, last known address and present whereabouts of every person known to you or to your attorneys or anyone acting in your behalf who has any knowledge regarding the facts, circumstances, or conditions surrounding the happening of the incident referred to in your Complaint, including but not limited to, eyewitnesses to such event, persons who were at or near the place of the alleged accident, and persons who claim to have been at or near the place of the alleged accident at the time it occurred or immediately before or immediately after its occurrence.

Please state the full name, last known address and present whereabouts of every person known to you or to your attorneys or anyone acting in your behalf who has any knowledge regarding the injuries you alleged in your Complaint.

Please state the name and address of each individual who has given a statement concerning this occurrence, stating for each individual the following: whether oral or otherwise; the date taken; the person taking the statement; the names and addresses of all people present; and the name and address of the person presently having custody of the statement.

Information About Other Claims

If you have made a claim of any kind with any insurance company as a result of the alleged accident, please state the name and address of the policyholders; the name and address of the insurer; and the amount of any claim paid under the policy and the date of payment.

If you have ever been involved in a lawsuit prior to the filing of this action, please state the names and addresses of the respective parties to such lawsuit, the subject matter of such lawsuit, and the manner of its disposition.

PREMISES LIABILITY -- If your claim involves a slip or trip, and fall situation, the following interrogatories are also likely to be asked.

Please state your familiarity with the premises where the alleged incident occurred, indicating the extent of your knowledge of the area and the number of times you had been there within twenty-four (24) months prior to the alleged occurrence.

Please state your reason for going to the premises where the incident allegedly occurred, where you had been immediately prior to arriving at the premises, how long you had been at the premises before your alleged fall and how long you remained at the premises following the alleged fall.

If you were carrying or holding anything at the time of the alleged occurrence, please describe such objects or property in complete detail, giving the weight and size of any such objects or property.

If it is your contention that the Defendant knew or should have known of an unsafe condition on their premises at the time of the incident in question, state each and every fact upon which you base such contention.

MOTOR VEHICLE COLLISION CASES -- If your injuries were caused by a motor vehicle accident, the following interrogatories are likely to be asked.

Please describe your vehicle at the time of the occurrence alleged in your complaint, including but not limited to the year, make and model of the vehicle; the mileage on the odometer at the time of the occurrence (indicating whether it was correct or not); the options on the vehicle at the time of the occurrence, whether it had any broken glass or non-working items or accessories, and a description of the general condition of the vehicle at the time of the occurrence; and whether the vehicle has ever been painted or had an engine overhaul and if so, the date and mileage on the vehicle at that time.

If the vehicle has been repaired since the accident, please state the following: the name, address and telephone number of each person or business performing the repairs; the date, time and place each such repair was performed; and the price paid for each such repair.

Have you received any estimates of the present value of the vehicle, or the cost to repair? If so, please state the following: the name, address and telephone number of the person making such estimate; the date, time and place the estimate was made; and whether the estimate was of its present value or the cost to repair and the amount of such estimate.

Were any pictures taken of the vehicle at the time of the incident? If so, state the name and address of the person or persons who took said photographs, and also the name and address of the party who has them in his possession at the present time.

With regard to the accident in question, state: the speed of the plaintiff's vehicle immediately prior to the accident; the speed of each defendant's vehicle immediately prior to the accident; and any action taken by any party, if any, to avoid the accident.

Describe in detail the road conditions where the accident occurred, stating specifically: how many lanes of traffic existed; whether there was any ongoing construction in the area; the weather conditions; and the road conditions.

During the twenty-four (24) hour period prior to the accident in issue, did you ingest any alcoholic beverage, narcotic drug or other medication? If so, please identify the substance, the quantity consumed, the time you consumed and the reason you consumed it.

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