Palm Beach County Florida Automobile Accident Discovery Call 1-800-74-TRIAL
1. Please identify yourself by stating full name, present address, date and place of birth, social security number, and name of spouse.

2. Please state the name, business address, and telephone number of each person who has assisted you in answering any part of these interrogatories.

3. Please state whether, at the time of the occurrence which is the subject of this claim, you had a prescription for glasses or corrective lenses and if so, please state the condition which the glasses or corrective lenses were designed to correct, for example, nearsightedness, farsightedness, etc. and whether or not you were wearing such glasses or corrective lenses at the time of the occurrence. Please state further the name and address of the person who prescribed such corrective lenses.

4. Please state whether you have ever been indicted or pled guilty to a felony or offense which was punishable by death or imprisonment for one year or more or involved dishon¬esty or false statement. If your answer is in the affirmative, please state the nature of the crime, date of conviction, title of the court in which the conviction is on file, and the sentence you received.

5. Please state the full name, address, and telephone number of each person who, to your knowledge or that of your agents or attorneys, was present at the scene of the occurrence which is the subject of this claim either immediately before, immediately after, or during such occurrence.

6. Have you or any persons acting on your behalf obtained any written or recorded statement from any person concerning the occurrence which is the subject of this claim? If so, please state:
a. The full name, address, and telephone number of the person who gave the written or recorded statement;
b. The name, address, and employment position of the person who took it;
c. The date it was taken;
d. Whether it was recorded or written;
e. Whether it was signed;
f. The present location of such statement, recording, or transcript;
g. Please attach a copy of such statement and if you object to providing such state¬ment, please state why.

7. Have you ever given a written or recorded statement other than to your attorney concerning the occurrence which is the subject of this lawsuit? If so, please state:
a. The name, address, and employment position of the person who took it;
b. Date it was taken;
c. Present location of the statement or transcript;
d. Please provide a copy of such statement and if you object to providing such statement, please state why.

8. Please state whether you, your agents, or attorneys have possession or knowledge of any photographs depicting the occurrence itself, scene of the occurrence, injuries of any party, or any other photograph depicting the subject of this claim. If so, please de¬scribe the nature of such photograph, state the name and address of the person or per¬sons in possession of either a print or negative of the photograph, and whether or not you will provide a copy of such photograph if the plaintiff agrees to reimburse you for the expense of such copies.

9. Please identify every expert witness, including physicians, whom you may or will call at trial by stating the name, address, and employment of such expert, along with the following information:
a. Qualifications as an expert;
b. Subject matter on which the expert is expected to testify;
c. The substance of the facts and opinions to which such expert may testify;
d. A summary of the grounds for each opinion.

10. If you were the driver of any vehicle involved in the claim which is the subject of this lawsuit, please state whether you consumed any alcoholic beverages, drugs, or medica¬tions of any kind whatsoever within 24 hours preceding the accident. If the answer is in the affirmative, please state the type of such consumption, amount, and the time at which such beverage, drug, or medication was consumed.

11. Please describe in narrative fashion and in as complete detail as possible the man¬ner in which the occurrence which is the subject of this claim happened including any events leading up to the occurrence, the events occurring immediately thereafter, and please include in your answer all events in their sequential order.

12. Please describe as completely as possible the weather, road conditions, lighting conditions, precipitation, if any, and temperature at the time the occurrence which is the subject of this claim happened.

13. Is it your contention, or that of your agents or attorneys, that any of the following caused or contributed to the occurrence which is the subject of plaintiff's claim or which contributed in any way to the injuries or damages claimed in plaintiff's complaint:
a. The negligence of any other party or defendant;
b. Negligence, including comparative negligence, of the plaintiff;
c. Any defect in any vehicle involved in the incident;
d. The negligent maintenance, inspection, repair, or service of any vehicle involved in the collision;
e. Weather conditions;
f. Any other factor known to you or your attorneys.

14. If your answer to any part of the preceding question was in the affirmative, please state:
a. Your contention as to each such cause or contributing factor;
b. The facts known to you, your agents, or attorneys which support such conten¬tions;
c. The name, address, and any other fact known about the person who caused or contributed to the incident;
d. An identification as to any writing, diagram, or report and whether or not you will produce such writing, diagram, or report;
e. The name, address, and telephone number of the person who is in custody of such writing or report of any nature which relates to the answers to interrogatory #13 above.

15. With respect to the automobile collision which is the subject of plaintiff's claim, please set forth:
a. Your estimate of speed at which your vehicle was traveling just prior to impact;
b. Your estimate of the speed at which any other vehicle involved in the incident was traveling just prior to impact.
c. Whether or not you were aware of the presence of other vehicles including that of the plaintiff just prior to impact;
d. Whether you applied your brakes at any time before the impact and if so, your best estimate as to how long in terms of seconds before impact you applied your brakes.
e. Whether or not your brakes locked or your wheels skidded prior to impact.

16. Please state whether or not you have driven in the same area in which the occur¬rence took place at any time prior to the date of the occurrence and if so, please estimate how many times you have driven through such area prior to the incident.

17. Please state whether or not you had a valid operator's license at the time of the incident and if not, please state why such license had been revoked, suspended, not reinstated, or not issued. If you had a valid license, please set forth:
a. The issuing state;
b. Restrictions and permissions on said license;
c. Date of issuance; and
d. Date of expiration.

18. Have you ever had your driver's license revoked or suspended prior to the incident which is the subject of this claim and if so, please set forth the state which revoked or suspended such license and the reason for such revocation or suspension.

19. If your vehicle was damaged as a result of this incident, please state:
a. Which parts of your vehicle were damaged;
b. The extent of such damage;
c. The cost of repair of such damage;
d. The name and address of the organization who made the estimate for repairs and/or who performed such repairs;
e. Please produce a copy of all property damage estimates.

20. With reference to each denial pleaded by you or your attorneys in the answer to plaintiff's complaint, please set forth with respect to each such denial:
a. All facts known to you, your attorneys, or agents which support or corroborate such denials;
b. The name, address, and telephone number of each such person known to you who claims to have knowledge regarding any such denials;
c. The name, address, and telephone number of any custodian of any writing or report which supports any denial of any of plaintiff's complaint.

21. If you deny that you were negligent in any way with respect to the injuries sustained by the plaintiff in the occurrence which is the subject of this claim, please state:
a. All facts known to you, your attorneys, or agents which support or corroborate your denial of negligence;
b. The name, address, and telephone number of any person known to you who has knowledge with respect to any denial of negligence;
c. The name, address, and telephone number of any custodian of any writing or report which supports any denial of any of plaintiff's complaint.

22. If you contend that the plaintiff was negligent or comparatively negligent with re¬spect to the plaintiff's own injuries, please set forth:
a. All facts known to you, your attorney, or agents which support or corroborate the allegation of negligence on the part of the plaintiff;
b. Name, address, and telephone number of any person known to you who has knowledge regarding any facts which support the allegation of negligence on the part of the plaintiff;
c. The name, address, and telephone number of any custodian of any writing or report which supports any denial of any of plaintiff's complaint.

23. Do you contend that any of the injuries or damages sustained by the plaintiff in the occurrence which is the subject of this claim were or are the result of any pre existing physical condition suffered or sustained by the plaintiff prior to the collision which is the subject of this claim and if so, please set forth:
a. Each and every fact which supports such contention;
b. The name, address, and telephone number of each and every person known to you who possesses knowledge of such fact; and
c. The name, address, and telephone number of any custodian of any writing or report which supports any denial of any of plaintiff's complaint.

24. Please state whether or not you received any traffic ticket, complaint, summons, warning, or citation arising out of this incident and if so, please state the nature of such ticket or citation, etc. and the final disposition of such ticket or citation, etc.

25. Please state whether you, your attorneys, insurance carrier, or any other agent has conducted any surveillance or observation of the plaintiff since the incident which is the subject of this claim and if so, please state:
a. The date and time of such surveillance or observation;
b. The name, address, job title, and position of the person who conducted such surveillance or observation;
c. The activities of the plaintiff on each such occasion;
d. The address or location of each surveillance or observation;
e. The custodian of any reports, photographs, video tapes, or other method of pre¬serving such surveillance or observation.

26. Please state whether or not you had an automobile insurance policy at the time of the incident which is the subject of this claim and if so, please set forth:
a. The name of the company issuing such policy;
b. The policy number;
c. Whether or not you are a named insured and the names of other insureds;
d. The limits of coverage including liability, medical payments, and other cover¬ages;
e. Please attach a copy of such policy and the declaration page with your answers to these interrogatories.

27. Please state whether you have made a reasonable and diligent effort to identify and provide not only facts within your knowledge, but also facts reasonably available to you with respect to every question asked in these interrogatories.