West Palm Beach Car Accident Sample Plaintiff to Defendant Interrogatories Call 1-800-74-TRIAL

1. State your correct legal name and any other names by which you have been known (either in a personal or corporate capacity), your 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 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 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. Specify whether you contend that the West Palm Beach Car Accident Plaintiff was responsible for the occurrence of the incident or the injuries resulting therefrom and state all facts on which you base 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 whether you contend that the West Palm Beach Car Accident Plaintiff suffered no loss of earning capacity as a result of the injuries sustained in the incident and state all facts on which you base any such contention.

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

14. 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 known to you who was present when each beverage was consumed.

15. 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 such drug

c. The time and place each such drug was taken

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

16. Specify whether you contend that you were acting within the scope of your employment, or acting as an agent of any other person or entity, at the time of the incident and, if so, specify:

a. The name and address of your employer or principal

b. Your position with the employer or principal

c. The exact nature of your duties at the time of the incident.

17. If you, or any representative of yours, at any time received any medical reports, X-ray reports or reports of other diagnosffc studies from any hospitals or physicians with respect to the injuries sustained in the incident, state:

a. When and from whom you or your representative received any such reports

b. The name and address of the person currently in possession or custody thereof.

18. Describe in detail whether you have been involved in a similar incident in the past, and, if so, specify:

a. The exact nature of the previous incident

b. When and where the previous incident occurred

c. Whether any litigation was commenced against you as a result of the previous incident, including the court, docket number and disposition of such litigation.

19. Identify all documents that you consulted in the preparation of any answer to these interrogatories.

20. Identify all photographs, voice or sound recordings, videotapes, motion pictures or films of the West Palm Beach Car Accident Plaintiff that you or any of your agents, representatives or employees have taken since the date of the accident.