Insured to Insurance Carrier Interrogatories – West Palm auto wreck bad faith

INTERROGATORIES

1. State your name, residential address, business address, employer, date of birth, social security number and the capacity in which you are answering these interrogatories.

2. State your exact title with the defendant carrier.

3. State how long you have held your present job title.

4. Give a detailed job description of your present position.

5. Identify all previous titles you have held with the defendant carrier including dates and specific job descriptions with regard to each.

6. Identify each and every employer for which you have worked within the past ten years including dates, job titles, and specific job descriptions for each.

7. Describe in detail your post high school educational background including all schools, colleges, other institutions which you attended; describe all degree programs you pursued; describe all degrees you have received including their dates; and describe all specialized courses, seminars or programs you have pursued or participated in.

8. Describe any publications you have authored that in any way relate to the insurance industry.

9. Describe each and every lecture, speech or other talk you have given that in any way relates to the insurance industry.

10. Describe each and every case for bad faith brought against the defendant carrier within the last ten years giving for each the name and address of the plaintiff and, if a lawsuit was filed, the caption of the case including the civil action number.

11. Describe each and every claim which arose out of a West Palm Beach Florida Accident brought against you for bad faith within the last ten years giving for each the name and address of the plaintiff and, if a lawsuit was filed, the caption of the case including the civil action number.

12. Describe each and every case for bad faith against any party in which you have answered interrogatories or otherwise acted as a witness.

13. Identify each and every policy which the plaintiff has had with the defendant carrier for the last ten years including policy numbers, dates, coverages, exclusions and liability limits.

14. State whether the defendant carrier continues to have copies of any of the policies (including facsimile copies) described in the previous answer.

15. Describe each and every claim which arose out of a West Palm Beach Florida Accident which the plaintiff has made against any of the policies you have described in your previous answers, including the dates of each claim, the nature of each claim which arose out of a West Palm Beach Florida Accident and their disposition.

16. State the date when the defendant carrier first received notice of the claim which arose out of a West Palm Beach Florida Accident at issue.

17. State the manner in which the defendant carrier received the first notice of the claim which arose out of a West Palm Beach Florida Accident at issue including the identity of the person receiving such notice.

18. Describe in detail each and every communication which the defendant carrier has had with the plaintiff after it received the first notice of the claim which arose out of a West Palm Beach Florida Accident at issue.

19. State whether a claim which arose out of a West Palm Beach Florida Accident file was opened for the claim which arose out of a West Palm Beach Florida Accident at issue and, if so, state when it was opened and to whom it has been assigned at any time.

20. Describe in detail the investigation the defendant carrier conducted into the claim which arose out of a West Palm Beach Florida Accident at issue.

21. State each and every basis upon which the defendant carrier has denied coverage/defense for the claim which arose out of a West Palm Beach Florida Accident at issue.

22. State each and every settlement demand which the defendant carrier has received from the claimant to settle the claim.

23. State the defendant carrier’s response to each settlement demand setting forth in detail the rationale, reasons and basis of each response.

24. If the defendant carrier contends that the plaintiff is not entitled to coverage because of his failure to comply with any condition of the policy, including notice conditions, describe each and every condition, and the manner in which the plaintiff’s failure to comply with each such condition has impaired the defendant carrier's rights.

25. If the defendant carrier contends that the plaintiff is not entitled to coverage because of its failure to give timely notice under the policy, state each and every action the defendant carrier would have undertaken had timely notice been given and the manner in which the lack of timely notice has affected the carrier’s rights to undertake any such action.

26. Identify all documents by nature (e.g., letter, memorandum, etc.) date, author, addressee and recipients upon which you relied or referred to in answering or attempting to answer any of the above interrogatories. Identify the interrogatories to which each such document relates.

27. Identify the person who currently has possession of each document identified in your previous answer.

28. Identify each person who participated in the preparation of any of your answers to these interrogatories, or who provided information or assistance in connection with the preparation of any answer, or whom you consulted or from whom you sought information or assistance in connection with the preparation of any answer. Identify the interrogatories to which each name applies.

29. Provide the name, address, area of expertise and qualifications of each expert retained by you who is expected to testify at trial, and with respect to each, provide:

(a) the subject matter on which he is expected to testify;
(b) the substance of every opinion to which he is expected to testify;
(c) the facts upon which he bases each opinion;
(d) a list of all documents, treatises and articles consulted by each expert in reaching his opinion;
(e) the basis and amount of each expert's compensation; and
(f) the relationship, if any, of each expert to the insurance industry.

Plaintiff
By His Attorneys,

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