Florida Car accident attorney Interrogatories to Accident Reconstruction Expert call 1800-HURT-911

Florida Car accident attorney Interrogatories to Accident Reconstruction Expert call 1800-HURT-911

The following interrogatories are designed to elicit information about an accident reconstruction expert who has been retained by the plaintiff or the defendant in a personal injury case. Review the local rules of procedure carefully to determine the scope and parameters of any witness discovery, as well as the rules pertaining to interrogatories generally before using or adapting these interrogatories.

1. Identify any person retained to testify as an expert who will offer any opinion testimony on accident reconstruction, including, but not limited to, (insert specifics of case as pertain to motor vehicle accident, product liability, etc.) and with respect thereto provide information as follows:
(a) Name, address and telephone number;
(b) Profession or occupation;
(c) Field of expertise;
(d) Formal education;
(e) Practical education;
(f) License certifications;
(g) Publications;
(h) Lectures, speeches, and seminars;
(i) Website.

2. Identify all actions (legal or administrative) in which the accident reconstructionist has proffered testimony (in fact or opinion) and include:
(a) The name, caption, number and any other means of identification;
(b) The subject matter of the testimony;
(c) The opinion or opinions rendered.

3. Does the accident reconstructionist have a curriculum vitae or résumé? If so, will you attach a copy to these responses rather than necessitate a formal request for production of documents? If so, please attach a copy. If not, please provide the date of the accident reconstructionist’s most recent curriculum vitae or résumé so that a formal request for production of documents can be made.

4. Identify any contact with the accident reconstructionist in this case, including:
(a) Contact by the attorney or the representative of [plaintiff or defendant, including any insurer];
(b) The purpose of the accident reconstructionist’s testimony;
(c) The “direction” or “charge” or “instructions” given to the accident reconstructionist, i.e., for what purpose was the accident reconstructionist retained and/or what was the accident reconstructionist asked to do?
(d) The amount of time that was spent by the accident reconstructionist on services rendered to [plaintiff or defendant].
(e) The accident reconstructionist’s fee for services rendered to [plaintiff or defendant], the basis for such fee, and any anticipated future fee prior to the conclusion of the case.

5. Was the accident reconstructionist retained under a written retention or engagement letter? If so, will you attach a copy of the engagement or retention letter to these responses rather than necessitate a formal request for production of documents? If so, please attach a copy. If not, pleased describe the date, author, signatory and anyone who received copies of the engagement or retention letter so that a formal request for production of documents may be made.

6. Identify all professionals who are assisting the [plaintiff or defendant], whether they are offering opinion testimony or otherwise, who have worked with the accident reconstructionist to prepare any report, conclusion or opinions, including:
(a) treating physician(s);
(b) impartial medical experts (IME);
(c) economist or medical economists;
(d) professional life care planners;
(e) other health care professionals;
(f) attorneys;
(g) insurance carriers or insurance representatives;
(h) engineers;
(i) ergonomists;
(j) forensic safety analysts.

7. Has the accident reconstructionist undertaken any testing or analysis/reviews or services for the [plaintiff or defendant]? If so, describe each in detail.

8. If the answer to interrogatory no. 7, in whole or in part, is yes, will you attach a copy of the results of any testing, analysis or reviews to these responses rather than necessitate the formal request for production of documents? If so, please attach a copy. If not, please describe the testing, analysis or review in sufficient detail so that a formal request for production of documents may be made.

9. Has the accident reconstructionist reached an opinion or conclusion with respect to any area on which he or she is expected to testify in the instant matter? If so, include:
(a) the substance of any opinion or conclusion;
(b) any facts or circumstances that serve as a basis for the opinion or conclusion.

10. If you are attaching a report prepared by the accident reconstructionist to these answers to interrogatories, please identify any prior drafts, the date of such prior drafts, who was involved in editing, revising, or modifying any prior drafts, and whether the prior drafts are still in existence. If they are in existence, will you attach a copy to these responses rather than necessitate a formal request for production of documents? If so, please attach. If not, please describe the date, author and anyone who received, edited, or modified copies of any prior drafts so that a formal request for production of documents may be made.