West Palm Beach Car Accident Sample Defendant to West Palm Beach Car Accident Plaintiff Interrogatories

1. State your correct legal name and any other names by which you have ever been known, address, marital status, age and occupation, both now and at the time of the incident.

2. List the names and addresses of all witnesses, or persons believed or known by you to have any knowledge concerning facts about the incident.

3. List each of the following:

a. The names and addresses of those persons who have given to you, your West Palm Beach Car Accident Attorney or any person, firm or corporation acting on your behalf, any statements, accident reports, voice recordings, medical proof of claim forms, reports or memoranda in any way concerning the incident

b. The date of each such statement, accident report, voice recording, medical proof of claim form, report or memorandum

c. The name, telephone number, and address of the person, firm or corporation who now has possession of same.

4. State the name, address or other information concerning the location of every person known or reasonably believed by you, your agent, investigators or other representatives to have knowledge, information or possession of any map, picture, photograph, drawing or other document about any issue or fact concerning the incident.

5. Did you give a statement or provide information to assist in the preparation of an accident report to any person, firm or corporation regarding this incident? If so, specify:

a. The date that each such statement was given

b. The name, address and occupation of the person to whom and for whom each such statement was given

c. The name and address of the person, firm or corporation having possession of each statement.

6. Have you ever been convicted of, or pleaded guilty or nolo contendere to any criminal offense? If so, specify:

a. The date of each such conviction or plea

b. The court and state of each such conviction or plea

c. The nature of each offense

d. The disposition of each charge.

7. Identify all persons whom you intend to call as expert witnesses at trial, and for each such expert specify:

a. The subject matter on which he or she is expected to testify

b. The substance of the facts and opinions to which he or she is expected to testify

c. A summary of the grounds for each opinion to which he or she will testify.

8. Identify all other experts consulted or engaged by you, your West Palm Beach Car Accident Attorney or your agents.

9. State whether there exists (and, if so, the contents of) any insurance agreement under which any person carrying on an insurance business may be liable to satisfy part or all of a judgment which may be entered in this action or to indemnify or reimburse you for payments made to satisfy such a judgment.

10. Do you contend that the defendant failed to exercise due care and, if so, state the facts on which you rely to support that contention.

11. Describe in detail how the incident occurred, giving all facts concerning the details of the events before, at the time of, and after the incident which you believe had any bearing on the incident.

12. Specify the time, place and substance of any conversation that you had, or which any person in your presence had, at the scene of the incident about the manner in which the incident happened.

13. State whether you consumed any intoxicating beverage within eight hours prior to the incident and, if so, specify:

a. The type of beverage or beverages

b. The quantity of each beverage

c. The time and place each beverage was consumed

d. The identity and location of each person who was present when each beverage was consumed.

14. State whether you took any drugs or narcotics (including prescription drugs) within 24 hours prior to the incident and, if so, specify:

a. The type of each such drug

b. The quantity of each drug

c. The time and place each such drug was taken

d. The identity and location of each person who was present when each such drug was taken.

15. Describe in detail the nature, extent and location of all injuries which you allege that you suffered as a result of the incident, and state which of those injuries you allege to be permanent.

16. List:

a. The name and address of each doctor or other health care provider who has treated you for the injuries alleged

b. The date of each such treatment

c. The nature of each such treatment

d. An itemized statement of the charges for each such treatment.

17. If you received treatment at a hospital or hospitals for the injuries which you alleged you sustained as a result of the incident, specify:

a. The name and address of each hospital

b. The date of each such treatment

c. The nature of each such treatment

d. Whether it was received as an in-patient or an out-patient
e. An itemized statement of the charges for each such treatment.

18. If you were employed or self-employed at the time of the incident, describe:

a. The nature of such employment and the length of time so employed

b. The name and address of your employer

c. Your average weekly or monthly earnings at the time of the incident

d. The period of time (inclusive dates) during which you allege you were prevented from totally or partially carrying on your usual occupation

e. Your actual total loss of earnings in dollars.

19. List all employment that you have had since graduating from high school, including the dates of each employment, your duties, compensation and any special training that you received with respect to each such employment.

20. If you have received any money or benefits under the Workers' Compensation Act in the form of partial settlement of any claim arising out of the incident from any person, firm or company, specify:

a. The name and address of the person, firm or company from whom you received such money or benefits

b. The date on which you received such benefits

c. The amount of benefits received

d. Whether you are willing to produce, on the defendant's request, a copy of any documents that you submitted to the person, firm or company from whom you received such benefits, and a copy of any agreement, covenant, release or discharge that may be in existence relative to such payments.

21. If you, at any time prior or subsequent to the incident, suffered an injury, disease or abnormality of a kind similar to those which you allege you suffered as a result of the incident, specify:

a. The nature of each such injury, disease or abnormality

b. The date and place that you suffered or incurred each

c. The names and addresses of all hospitals, doctors or other health care providers who treated you for each such injury, disease or abnormality

d. The dates of such treatments

e. The names and addresses of any and all persons against whom any claim was made or action commenced (giving the name and location of any applicable court or commission) as a result of each such injury, disease or abnormality.

22. State whether, since the incident at issue, any photographs, videotapes or motion picture films were taken of you or the scene of the incident. If so, specify:

a. The date or dates of the taking of such photographs, videotapes or motion picture films

b. The name and address of the person or persons presently having possession of each.

23. Give a complete and detailed list of every activity which you allege you are or have been unable to engage in as a result of the injuries at issue.

24. Give a complete itemization of the West Palm Beach Car Accident damages that you claim you have suffered as a result of the incident.

25. State whether you have undergone any of the following medical procedures or diagnostic tests:

a. X-rays
b. CAT scans
c. Myelogram
d. Discogram
e. Thermogram
f. Electromyogram (EMG)
g. Magnetic resonance imaging (MRI)
h. Tests for temporomandibular joint syndrome (TMJ)
i. Cervical disc distension test
j. Radionuclide bone scans
k. Videofluoroscopy
l. HLA-B27 testing
m. Epidural venogram
n. Arthroscopy
o. Arthrography.

26. With respect to any of the foregoing treatments that you have undergone, specify:

a. The physician and/or clinician who prescribed and/or administered such treatment or diagnostic technique

b. When, where and under what conditions each such treatment and/or diagnostic technique was administered

c. The instructions that you were given regarding each such treatment, prior to, at the time of, and subsequent to each (e.g., refrain from smoking, avoid caffeine, avoid the use of ointments, avoid alcohol, etc.).

27. State whether any physician has ever prescribed medication for the injuries which you allege you sustained as a result of the incident and, if so, specify:

a. The physician or physicians prescribing each

b. The type of medication prescribed

c. The inclusive dates during which you took such medication

d. The pharmacy or pharmacies where you filled each such prescription

e. Whether you have been prescribed, or have taken, any of the following analgesics:

i) Aspirin
ii) Darvon
iii) Parafon Forte
iv) Codeine
v) Percodan
vi) Demerol
vii) Morphine

f. State whether you have ever been prescribed, or have taken, any of the following anti-inflammatory drugs:

i) Aspirin
ii) Motrin (ibuprofen)
iii) Nalfon (phenoprofen)
iv) Naprocyn (naproxen)
v) Tolectin (tolmetin)
vi) Indocin (indomethacin)
vii) Butazolidin (phenylbutazon)
viii) Clinirol (sulindac)
ix) Meclomen (meclofenemate)

g. State whether you have ever been prescribed, or have taken, Chymopapain.

28. State whether any physician ever confined you to bedrest as a result of the injuries which you allege you sustained and, if so, specify:

a. The physician or physicians

b. The inclusive dates during which you were confined to bed rest.

29. State whether any physician ever prescribed traction as a result of the injuries that you allege you sustained and, if so, specify:

a. The physician or physicians

b. The inclusive dates during which you were confined to traction.

30. State whether any physician ever prescribed a TENS unit (transcutaneous electronic nerve stimulator) as a result of the injuries that you allege you sustained and, if so, specify:

a. The physician or physicians

b. The inclusive dates during which you used a TENS unit.

31. State whether any physician has ever prescribed physical therapy for the injuries which you allege you sustained and, if so, specify:

a. The physician or physicians

b. The inclusive dates during which you received such therapy

c. The nature of the therapy given to you

d. Where each such therapy session was conducted

e. Whether you were ever given a home therapy program

f. State specifically whether any of the following physical therapy
treatments has been employed:

i) Cryotherapy
ii) Heat application
iii) Massage

32. State whether any physician has ever prescribed surgery for the injuries that you allege you sustained and, if so, specify:

a. The physician or physicians

b. Whether surgery was performed

c. The nature of such surgery

d. When and where each such surgery was performed.
33. If surgery was prescribed and not performed, state why.

34. State whether you have undergone any other treatment, diagnostic studies or therapy that you have not set forth above and, if so:

a. The nature of the treatment, study or therapy which you underwent

b. The identity of the physician or physicians prescribing each

c. When and where you underwent each.

35. State whether you have made a claim against any third party for insurance or other benefits as a result of the incident at issue.