West Palm Beach | SAMPLE INTERROGATORIES FROM DEFENSE COUNSEL IN AN AUTOMOBILE CASE

QUESTION #1:
Please identify yourself by stating your full name, present address, present employment position, if any, date of birth, the full name and present address of your spouse, if you are married, your height and weight as of the time of the incident referred to in the Complaint, Social Security number, and the names and ages of your children, if any.
QUESTION #2:
Please state the full names, current addresses, employment positions and employers of each and every person who, to your knowledge or to that of your agents, attorneys, or employees, have knowledge of any of the facts concerning the incident referred to in the Complaint. Identify all documents which relate to each of these persons and the incident.
QUESTION #3:
State the full name, current address and employment position of each person who investigated on your behalf the matters which are the subject of this suit. Identify each and every document which relates in any way to this Interrogatory answer.
QUESTION #4:
Set forth in full the substance of any admission by a party or by an alleged agent of a party, and include within your answer the name of the person making each such admission, the date and time of the admission, and the name and address of all persons present at the time of the admission. Identify each and every document which relates in any way to each such admission.
QUESTION #5:
List the names, addresses, official titles, if any, home and work addresses and telephone numbers of all witnesses, including expert witnesses, who it is contemplated will be called upon to testify in support of your position in this action, indicating with respect to each the nature and substance of the testimony expected to be given and stating the relationship, if any, of the witness to you.
QUESTION #6:
State whether you, your agents, or attorneys have ever seen or have knowledge of any photographs, videotapes, films, or movies of, or relating to, the incident. If so, state the full name, current address and employment position of each person now in possession of any such materials. Identify each and every document which relates to every single one of these materials, as well as the materials themselves.
QUESTION #7:
Please itemize in complete and exhaustive detail each and every element of damage which you claim or contend is associated with the incident. Identify all documents presently in your possession, or of which you, your agents, servants, employees or attorneys are aware, which in any way substantiates these damages.
QUESTION #8:
If you, or anyone on your behalf, has obtained any statements concerning the accident which is the subject matter of this lawsuit, describe separately each such statement by setting forth the name and address of the person who gave it, the name, address and employment position of the person who took it, the date it was taken, whether it was written or recorded, whether it was reduced to writing, whether it was signed and the present location of all notes, recordings, transcripts, or other writings of any kind pertaining to each statement.
QUESTION #9:
If you ever prepared, submitted or made any written statements or reports describing the accident, please state the date of any such statement or report, the substance of the contents of any such written report, the person to whom the statement or report was made, the present custodian of the original of the statement and whether a copy of the statement or report is in your possession or custody.
QUESTION #10:
If you have made an insurance claim or have been reimbursed by any insurer for any of the losses or damages claimed in this suit, state with respect to each such claim or reimbursement the name and address of the insurer, the policy number under which the claim or reimbursement was made, the nature of insurance coverage provided, the amount claimed, and the amount of each reimbursement made. Identify all documents which relate in any way to the claim or reimbursement.
QUESTION #11:
If at the time of the occurrence which is the subject of this suit there was any policy of liability insurance affording coverage to you or the operator of the automobile which you occupied at the time of the occurrence, state with respect to each such policy the name and address of each named insured, the name and address of the insurer, the policy number, the limits of bodily injury and property damages liability protection, and the nature of each coverage defense, reservation of right and non waiver agreement, if any, that the insurer has asserted or entered into with respect to this occurrence.
QUESTION #12:
If you claim to have sustained any loss of income as a result of the incident, state the full amount claimed to have been lost, the sources from which you would have received it, and the inclusive dates during which you lost it. Please also set forth in complete and exhaustive detail your analysis of how the loss was computed. Identify all documents which in any way relate to this claim.
QUESTION #13:
State the full name and last known address of each of your employers during the ten year period immediately preceding your answers to these Interrogatories and include within your answer the dates of your employment with each such employer and a description of the duties assumed and services rendered by you in connection with each such employment.
QUESTION #14:
If you have applied for benefits of any kind to any state or federal agency, state the date of each such application, the complete name and address of the governmental office to which the application was directed, whether it was approved, the total amount paid, the period of time during which benefits were paid and/or the reasons for each such rejection and/or termination of benefits. Identify all documents which relate to such benefits.

QUESTION #15:
If you have ever pleaded guilty to or been convicted of any crime that was punishable by death or imprisonment for one year or more or involved dishonesty or false statement within the past ten years please state the nature of the offense, the date of false statement within the past ten years, and please state the nature of the offense, the date of your conviction, the county and state in which you were tried, and the sentence given to you.
QUESTION #16:
State whether or not you were receiving unemployment benefits prior to your accident, and please state the amount of income derived from that source.
QUESTION #17:
State whether or not you have been receiving unemployment benefits subsequent to the alleged accident, and please state the amount of income derived from that source.
QUESTION #18:
Please state in complete and exhaustive detail your personal knowledge of how the accident, which is the subject of this lawsuit, took place, setting forth the events in the order in which they occurred.
QUESTION #19:
Please describe in detail the movements of the vehicle in which you were riding immediately following the collision, including, but not limited to the path your vehicle took following the collision, the location of your vehicle when it finally came to a stop, the means by which your vehicle finally came to a stop and whether your vehicle forcibly contacted any objects following the collision.
QUESTION #20:
Please describe in detail the movements of your body within the vehicle in which you were riding immediately following the impact, including but not limited to the path your body took through the interior of the vehicle, each and every part of your body that struck the interior of the vehicle and each and every part of the vehicle against which your body struck.
QUESTION #21:
Please describe in detail the means by which you left the accident scene, and if you left with assistance, please indicate the name and address of each and every person, organization, and or ambulance service that gave you assistance.
QUESTION #22:
State in detail the nature of the injuries you allege you suffered as a result of the incident referred to in the Complaint.
QUESTION #23:
Please identify each and every physician, technician, physical therapist, hospital, laboratory, clinic or other medical person or facility by whom or at which you have been examined, tested or treated during the ten year period immediately preceding the date of the incident. Include within your answer the inclusive dates during which each such exam, test or treatment occurred, together with the name, type and/or description of each such examination, test or treatment and the reason therefor.

QUESTION #24:
Please identify each and every physician, technician, physical therapist, hospital, laboratory, clinic or other medical person or facility by whom or at which you have been examined, tested or treated from the date of the incident up to and including the present date; and include within your answer the dates of each exam, test or treatment, and the name, type and/or description of each such examination, test or treatment, and the reason therefor.
QUESTION #25:
If you have had physical complaints of any kind since the incident, set forth in complete and exhaustive detail the nature of each such complaint, including the dates and times of each complaint; and describe the frequency, intensity and duration of each complaint.
QUESTION #26:
For every pharmacy that filled prescriptions issued to you or on your behalf in the five (5) years immediately preceding the incident of which you complain, identify the name and address of the pharmacy, the name and address of the prescribing physician, and of the complaint or condition you understand the prescription medication or device addressed.
QUESTION #27:
If you have been or expect to be a party to any other suit, claim or workers’ compensation proceeding relating to any personal injury, occupational disease or physical disability sustained by you, including the injury of which you presently complain, describe completely the nature of each such suit, claim or proceeding, including the forum, the parties, the date of filing, a brief description of the injury, disease or disability forming the basis for the claim, and the disposition of the suit or claim.
QUESTION #28:
Identify each year in the five years immediately prior to the event which is the subject of this litigation, in which you did not file a federal income tax return, and for each year identified, state the reason for your failure to file.
QUESTION #29:
For every accident in which you were ever involved, including but not limited to motor vehicle accidents, identify the date, place, a description of the damage to both property and person, the names and addresses of persons involved, and a summary of what happened.
QUESTION #30:
With respect to the damage to the vehicle you were occupying, sate in detail the part or parts damaged, the extent of damage and the cost of repair.
QUESTION #31:
For every crime for which you pled guilty or were convicted which was either 1) punishable by death or imprisonment for one year or more under the law under which you were convicted, or 2) involved dishonesty or false statement, regardless of punishment, identify the date of conviction, the court, the sentence, and the date of your discharge from the sentence, if that has occurred.

QUESTION #32:
If you claim to have sustained any permanent impairment to your person as a result of the incident, describe each part of your person that you claim is permanently impaired by the incident, stating the degree of each impairment. Identify and state a summary of the qualifications of each medical expert whom you plan and/or intend to present to testify at trial concerning your claim for permanent impairment. For each such expert witness, state the substance of all facts and opinions to which the witness is expected to testify and a summary of the grounds for each opinion he will give.
QUESTION #33:
If you were at any time confined as a result of the injuries sustained in this accident, please describe in detail the period of time you were confined in any hospital, the period of time you were confined to bed and the period of time you were confined to your home.
QUESTION #34:
Please describe in complete and exhaustive detail your symptoms at the present time, including the sites and intensities of any pain.
QUESTION #35:
Please describe in complete and exhaustive detail any and all injuries, painful symptoms, and/or congenital defects you had suffered before the incident, and further indicate how recently before the incident you had been treated for such difficulties, by date.

QUESTION #36:
Please describe in detail each and every occupational and avocational activity which you were able to perform before the incident that you were unable to perform to any extent as a consequence of the incident.
QUESTION #37:
If you claim or contend that you are entitled to damages for pain and suffering, please list in precise detail each and every occurrence, symptom or other factor which in any way supports this claim or contention.