(WEST PALM BEACH FLORIDA CAR ACCIDENT PLAINTIFF’S) INTERROGATORIES AND
REQUEST TO PRODUCE REGARDING DEFENDANT’S MEDICAL EVALUATOR(S) OF PLAINTIFF Call 1-800-74-TRIAL

Plaintiff, by and through Counsel, Law Offices of _____, hereby requests that the following Interrogatories, submitted under _____ Court Rule, be answered under oath by you, your agents, representatives, or attorney, who is competent to testify on your behalf concerning the facts about which inquiry is hereby made; and that the answers be served on the undersigned Attorney for Plaintiff within twenty-eight (28) days from the date these Interrogatories are served upon you.
These Interrogatories are deemed continuing and you are requested to provide, by way of supplementary answers, such additional information as may hereafter be obtained by you or any person on your behalf which will augment or otherwise modify answers now given.
These Interrogatories refer to the date of accident in question as stated in (West Palm Beach Florida car accident Plaintiff’s) Complaint.
1. State the total anticipated and/or actual charges paid by defense counsel or insurance company for the examination of Plaintiff and report that was prepared by the examining physician. If there was more than one defense medical examination (DME) please answer as to each evaluation.
ANSWER 1.
2. State the anticipated charge for the testimony of defense medical examiner who [will examine/examined] Plaintiff.
ANSWER 2.
3. State the number of occasions in the past forty-eight (48) months that the Defendant’s law firm has retained the defense medical examiner who [evaluated/will evaluate] Plaintiff. If there was more than one defense medical examination (DME), please answer as to each evaluation.
ANSWER 3.
4. State the number of occasions in the past forty-eight (48) months that the defense medical examiner has performed independent or adverse medical examinations for the insurance company who insures the Defendant in this cause of action.
ANSWER 4.
5. State the number of occasions in the past forty-eight (48) months that the defense medical examiner has performed independent or adverse medical examinations for any Defendant, insurance company or defense attorney, excluding what is listed in Interrogatory #4 above.
ANSWER 5.
6. State the total number of gross billings the defense medical examiner or the company, corporation or agency that set up the examination has charged to insurers, insurance defense attorneys and Defendants in the last four (4) years to perform independent or adverse medical examinations.
ANSWER 6.
7. State the total amount the defense medical examiner has earned, net of any fees or costs paid to any other person, company or agency in the last four (4) years to perform independent or adverse medical examinations.
ANSWER 7.
8. State the gross income earned by the defense medical examiner in the last four (4) years for depositions or trial testimony.
ANSWER 8.
9. List all articles written by defense medical examiner, including the name of the article, the name of the publications, the date, page number and volume or issue number and content and subject. If they are all listed on the defense medical examiner’s curriculum vitae, please attach same in lieu of answering this question.
ANSWER 9.
10. Please attach to your Answers to Interrogatories, a copy of all 1099s issued to each and every one of Defendant’s medical examiner(s) issued by defense law firm, agencies that primarily handle defense medical evaluations and insurance companies for independent or adverse or defense medical evaluations in the last four (4) years.
(WEST PALM BEACH FLORIDA CAR ACCIDENT RELATED ANSWER) 10.
11. As to each and every medical evaluator who has seen or may see Plaintiff, state:
A. Their name and address;
B. The education background of each expert witness and include the following as to each individual:
1) Name and address of college or university including any postgraduate education;
2) Dates of attendance of each;
3) Nature and scope of education received;
4) Whether or not any of the above schools were accredited;
5) Training in any specialty;
6) Degrees received;
a. Dates each degree was received;
b. Any honors received;
7) If said expert did not graduate from any educational facility he/she attended, please state:
a. Reason for failure to graduate;
b. Amount of required program not completed.
C. Please state the prior work experience of each expert and for each one include:
1) Employers for the past ten (10) years;
2) Title or positions held;
3) Duties and responsibilities;
4) Special training or experience;
5) Any other experience which said expert will rely upon in formulating any opinion relative to this litigation.
(WEST PALM BEACH FLORIDA CAR ACCIDENT RELATED ANSWER) 11.
12. Does the defense medical examiner (DME), or professional corporation or facility with whom he/she is associated, maintain said defense medical examiner’s scheduling calendars for the last five years? If so, please state:
A. The name and address of the person having possession of the afore mentioned scheduling calendars of said defense medical examiner;
B. Has each defense medical examiner ever been a plaintiff or defendant in a legal action? If so, please state:
1) The complete caption of the case;
2) The docket number of the case and the Court where the action was pending;
3) The date the case was filed;
4) The subject matter of the litigation;
5) The disposition of the case;
6) The names of the attorneys for each party to the litigation.
(WEST PALM BEACH FLORIDA CAR ACCIDENT RELATED ANSWER) 12.
13. What percentage of the defense medical examiner’s income is derived from medical/legal review?
(WEST PALM BEACH FLORIDA CAR ACCIDENT RELATED ANSWER) 13.
14. Please produce a complete copy of the defense medical examiner’s legal/medical file regarding Plaintiff.
(WEST PALM BEACH FLORIDA CAR ACCIDENT RELATED ANSWER) 14.
15. If the defense medical examiner works for an agency, corporation or otherwise, whose business is it to set up and schedule the medical evaluations, please indicate the office manager’s name and address of that facility.
(WEST PALM BEACH FLORIDA CAR ACCIDENT RELATED ANSWER) 15.
16. What percentage of defense medical examiner’s time is spent doing medical evaluations?
(WEST PALM BEACH FLORIDA CAR ACCIDENT RELATED ANSWER) 16.
17. What is the defense medical examiner’s remaining time spent doing and where?
(WEST PALM BEACH FLORIDA CAR ACCIDENT RELATED ANSWER) 17.
18. What is the name and address of person (West Palm Beach Florida car accident related ANSWER)ing these Interrogatories?
(WEST PALM BEACH FLORIDA CAR ACCIDENT RELATED ANSWER) 18.
Respectfully Submitted:
LAW OFFICES OF ________________
Attorneys for Plaintiff
_______________________________
[Attorney]
Dated: ____
The above (West Palm Beach Florida car accident related ANSWER)s are true to the best of my knowledge, information and belief.
Interrogatories (West Palm Beach Florida car accident related ANSWER)ed by: ________________
Defendant
Dated: _____