Auto Accident Interrogatories Propounded by Plaintiff
Auto Accident Interrogatories Propounded by Defendant
1.
Please state:
(a)
The name and address of the person or persons answering these interrogatories;
(b)
His/her relationship to defendant; and,
(c)
His/her position of employment.
2.
Background Information: Please state:
(a)
Defendant's full name;
(b)
Name of defendant's spouse;
(c)
Defendant's maiden name, if applicable;
(d)
Defendant's age and date of birth;
(e)
Defendant's Social Security number;
(f)
Defendant's present address;
(g)
Any other addresses at which defendant has lived during the past five years;
(h)
Defendant's present employer's name and position of employment; and,
(i)
Previous employers' names for the past five years and the dates of employment
there.
3.
Statements: Are you aware of any statement made by plaintiff (or its employees)
regarding the occurrence mentioned in the petition, whether oral, written, or
recorded in any way, including but not limited to, a stenographic, mechanical,
electrical, audio, video, motion picture, photograph, or other recording, or
transcription thereof, and if so, state the following:
(a)
Date, place, and time taken;
(b)
Name and address of the person or persons connected with taking it;
(c)
Names and addresses of all persons present at the time it was taken;
(d)
Whether the statement was oral, written, shorthand, recorded, taped, etc.;
(e)
Was it signed?
(f)
Names and addresses of the persons or organizations under whose direction and
upon whose behalf it was taken or made; and,
(g)
Please attach an exact copy of the original of said statement, interview,
report, film or tape to your answers to these interrogatories; if oral, please
state verbatim the contents thereof.
4.
Photographs: State whether there exists photographs, videotapes, or movies with
respect to the automobiles or scene of the occurrence mentioned in the petition.
If so, state the following:
(a)
Describe each photograph, video, or movie;
(b)
State the date each was taken;
(c)
State the name and address of the person taking each such photo, video, or
movie; and,
(d)
State the name and address, employer, insurer, and job title of the person
presently having control or custody of each photograph, video or movie.
5.
Experts: List and identify:
(a)
Each person this defendant expects to call as an expert witness at the trial,
whether the witness is a retained expert or non-retained expert, stating for
each such expert:
(i)
Name;
(ii)
Address;
(iii)
Occupation;
(iv)
Place of employment;
(v)
Qualifications to give an opinion (if such information is available on an
expert's curriculum vitae, you may attach a copy thereof in lieu of
answering this interrogatory subpart); and,
(b)
With respect to each expert listed, please state the subject matter on which
the expert is expected to testify and the expert's hourly deposition fee.
6.
Witnesses: State the names and addresses of every person known by defendant,
defendant's representatives or defendant's attorney, to have witnessed the
occurrence mentioned in the petition, or who was present at the scene within
sixty minutes of the occurrence. Designate which of such people actually claim
to have witnessed the occurrence.
7.
Criminal Record: State whether defendant has ever pleaded guilty to or has ever
been convicted of a felony or misdemeanor, (State or Federal) and if your answer
is in the affirmative, please state:
(a)
The date of any such plea or conviction;
(b)
The state and county where said plea or conviction occurred; and,
(c)
The offense for which defendant pled guilty or was convicted.
8.
Destination, Etc.: State where defendant was coming from and the place of
defendant's destination at the time of the collision in question.
9.
Auto Ownership and Property Damage:
(a)
State the name and address of any and all registered or equitable owners of
the vehicle being operated by defendant at the time of the occurrence in
question.
(b)
State whether repair estimates were obtained or the vehicle was repaired, and
if so, please state the amounts of any estimates and/or repair costs and the
names and addresses of each person or company who prepared an estimate or
repaired the vehicle.
10.
Violations: State whether defendant or defendant's representatives was/were
convicted of or pleaded guilty to any violation arising out of the collision in
question, and if so, state the charges to which such person was convicted or
pled guilty, the name and address of the court where same occurred, the date of
final disposition, and the cause number for each such plea or conviction.
11.
Insurance: State whether or not any insurance company (including any company
with excess or umbrella coverage) has an interest in the outcome of this
litigation against defendant. If so, state the following:
(a)
The name of the insurance company;
(b)
Whether the insurance company is a stock company or a mutual company;
(c)
Name of the insured;
(d)
Type(s) of insurance;
(e)
Effective policy period;
(f)
Policy number;
(g)
Limits of the policy applicable to the occurrence mentioned in these
pleadings; and,
(h)
Whether the policy provides for medical payments coverage, and if so, the
amount of coverage.
12.
Alcohol, etc.: State whether the defendant consumed alcoholic beverages,
medication, or prescription or non-prescription drugs within a ten (10) hour
period prior to the collision in question, and if so, state the names and
addresses of the places where said alcoholic beverages, medication or drugs were
consumed and described the quantity and type of drinks, medication or drugs
which were consumed in said period of time.
13.
Mechanical Defects: State whether a claim is made that there was a mechanically
defective condition or mechanical failure of the vehicle being operated by
defendant at the time of the collision in question which contributed to cause
the collision in question and if so, state the nature of said mechanically
defective condition of the vehicle and what actually occurred to contribute to
the cause of the accident in question.
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"save link as" in Netscape).
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1.
Please state:
(a)
The name and address of the person or persons answering these interrogatories;
(b)
His/her relationship to plaintiff; and,
(c)
His/her position of employment.
2.
Background Information: Please state:
(a)
Plaintiff's full name;
(b)
Name of plaintiff's spouse and date of marriage;
(c)
Plaintiff's maiden name, if applicable;
(d)
Plaintiff's age and date of birth;
(e)
Plaintiff's Social Security number;
(f)
Plaintiff's present address;
(g)
Any other addresses at which plaintiff has lived during the past five years;
(h)
Plaintiff's present employer's name and position of employment; and,
(i)
Previous employers' names for the past five years and the dates of employment
there.
(j)
Whether or not at the time of the collision referred to in plaintiff's
petition, this defendant was performing any business task or job at the
request of or on behalf of defendant's employer, and if so, please state the
nature of the task or job being performed and the name of the employer.
3.
Statements: Are you aware of any statement made by defendant (or its employees)
regarding the occurrence mentioned in the petition, whether oral, written, or
recorded in any way, including but not limited to, a stenographic, mechanical,
electrical, audio, video, motion picture, photograph, or other recording, or
transcription thereof, and if so, state the following:
(a)
Date, place, and time taken;
(b)
Name and address of the person or persons connected with taking it;
(c)
Names and addresses of all persons present at the time it was taken;
(d)
Whether the statement was oral, written, shorthand, recorded, taped, etc.;
(e)
Was it signed?
(f)
Names and addresses of the persons or organizations under whose direction and
upon whose behalf it was taken or made; and,
(g)
Please attach an exact copy of the original of said statement, interview,
report, film or tape to your answers to these interrogatories; if oral, please
state verbatim the contents thereof.
4.
Photographs: State whether there exists photographs, videotapes, or movies with
respect to the automobiles or scene of the occurrence mentioned in the petition.
If so, state the following:
(a)
Describe each photograph, video, or movie;
(b)
State the date each was taken;
(c)
State the name and address of the person taking each such photo, video, or
movie; and,
(d)
State the name and address, employer, insurer, and job title of the person
presently having control or custody of each photograph, video or movie.
5.
Experts: List and identify:
(a)
Each person this defendant expects to call as an expert witness at the trial,
whether the witness is a retained expert or non-retained expert, stating for
each such expert:
(i)
Name;
(ii)
Address;
(iii)
Occupation;
(iv)
Place of employment;
(v)
Qualifications to give an opinion (if such information is available on an
expert's curriculum vitae, you may attach a copy thereof in lieu of
answering this interrogatory subpart); and,
(b)
With respect to each expert listed, please state the subject matter on which
the expert is expected to testify and the expert's hourly deposition fee.
6.
Witnesses: State the names and addresses of every person known by plaintiff,
plaintiff's representatives or plaintiff's attorney, to have witnessed the
occurrence mentioned in the petition, or who was present at the scene within
sixty minutes of the occurrence. Designate which of such people actually claim
to have witnessed the occurrence.
7.
Criminal Record: State whether plaintiff has ever pleaded guilty to or has ever
been convicted of a felony or misdemeanor, (State or Federal) and if your answer
is in the affirmative, please state:
(a)
The date of any such plea or conviction;
(b)
The state and county where said plea or conviction occurred; and,
(c)
The offense for which plaintiff pled guilty or were convicted.
8.
Destination, Etc.: State where plaintiff was coming from and the place of
plaintiff's destination at the time of the collision in question.
9.
Auto Ownership and Property Damage:
(a)
State the name and address of any and all registered or equitable owners of
the vehicle being operated by plaintiff at the time of the occurrence in
question.
(b)
State whether repair estimates were obtained or the vehicle was repaired, and
if so, please state the amounts of any estimates and/or repair costs and the
names and addresses of each person or company who prepared an estimate or
repaired the vehicle.
10.
Violations: State whether plaintiff or plaintiff's representatives was/were
convicted of or pleaded guilty to any violation arising out of the collision in
question, and if so, state the charges to which such person was convicted or
pled guilty, the name and address of the court where same occurred, the date of
final disposition, and the cause number for each such plea or conviction.
11.
Alcohol, etc.: State whether the plaintiff consumed alcoholic beverages,
medication, or prescription or non-prescription drugs within a ten (10) hour
period prior to the collision in question, and if so, state the names and
addresses of the places where said alcoholic beverages, medication or drugs were
consumed and described the quantity and type of drinks, medication or drugs
which were consumed in said period of time.
12.
Injuries: State the parts of plaintiff's body, if any, injured in the occurrence
mentioned in the petition, and for each part of his/her body so injured state
the following:
(a)
The date of onset of any symptoms claimed to be related to each such alleged
injury;
(b)
Whether plaintiff continues to have complaints with respect to that part of
his/her body.
13.
Other Illnesses or Injuries: Has plaintiff had any illnesses, impairment or
injuries to the parts of the body injured in the occurrence mentioned in the
petition, either before or after the collision which is the subject of this
lawsuit?
(a)
The date sustained or suffered;
(b)
The parts of the body involved;
(c)
The nature or type;
(d)
The name and address of each health care provider who treated or examined
plaintiff.
14.
Claims and Lawsuits: Has plaintiff ever filed another lawsuit, made a claim for
bodily injury, or filed a workers' compensation claim?
(a)
The date filed or lodged;
(b)
The nature or type of lawsuit or claim
(c)
The name of the court, commission or other body in which the claim or lawsuit
was brought;
(d)
The illnesses, injuries or physical condition alleged;
(e)
State whether any money was received, whether by settlement or trial, and if
so, the amount; and,
(f)
The names and addresses of all health care providers who treated plaintiff or
examined plaintiff for the claim or lawsuit.
15.
Settlements: Has plaintiff received any settlement monies or other thing of
value from any person, company, firm, corporation or association involved in
this occurrence as a settlement, in whole or in part, of your claim? If you
answered "YES" to this question, please state the following:
(a)
The name and address of the person, firm, association, company or corporation
from whom any such settlement was made;
(b)
The name and address of the person, firm, association, company or corporation
on whose behalf any such settlement was made;
(c)
The amount or value of any such settlement;
(d)
Whether any forms or papers (settlement documents) were executed, excluding
statements of the facts, and describe and identify the nature of any such
papers or documents;
(e)
If you do not possess or have access to the papers or forms (settlement
documents) mentioned in Number (d) above, then state the name and address of
the person, firm, association, company or corporation that has possession of
said papers or forms (settlement documents).
16.
Amount Claimed: Pursuant to R.S.Mo. 509.050, what dollar amount of damages is
plaintiff seeking as compensation for your injuries? Please specify the personal
injury damages and property damages claimed.
17.
Medical Care: State the names and addresses of all doctors, hospitals or health
care providers who have treated examined or attended plaintiff since the
occurrence in question and because of it, and for each listed, please state:
(a)
The amount of the bill from each such health care provider for services
rendered because of the occurrence in question;
(b)
The number of visits and the specific dates of each visit plaintiff has made
to each of these health care providers because of the occurrence;
(c)
The conditions for which plaintiff was examined or treated; and,
(d)
If you claim that plaintiff received a medical examination, care or treatment
because of the occurrence mentioned in the petition, please sign and return
the attached medical authorization, after inserting the names and address of
the doctors, hospitals or health care providers.
18.
Lost Wages: Does plaintiff claim a loss of earnings, wages or income as a result
of the occurrence? If so, please state:
(a)
The name and address of plaintiff's employer at the time of the occurrence.
(b)
The rate of pay with that employer;
(c)
The amount of plaintiff's claim and show exactly how that amount was
calculated;
(d)
List each day, by specific date, that plaintiff claims he/she has been unable
to work because of the occurrence;
(e)
If plaintiff had a loss of income other than missing time from work, state the
amount of the loss, the nature of the loss, and how the amount of the loss was
calculated; and,
(f)
Please sign the attached employer authorization and insert the name and
address of the employer.
19.
Property Damage: Is plaintiff making any claim for property damages? If so,
please state:
(a)
The name and address of any and all registered or equitable owners of the
vehicle being operated by plaintiff at the time of the occurrence in question;
and,
(b)
Whether repair estimates were obtained or the vehicle was repaired, and if so,
please state the amounts of any estimates and/or repair costs and the names
and addresses of person or company who prepared an estimate or repaired the
vehicle.
20.
Disability Application: Please state whether or not plaintiff has ever applied
for any type of disability benefit from any entity (governmental, insurance,
employer), and if so, please state:
(a)
The date of each application;
(b)
The name and address of the entity;
(c)
The reason for the application (i.e., the nature of the injury causing the
disability);
(d)
Whether or not any disability benefits were actually received; and,
(e)
When payment of the benefits began and when it ended.
21.
Mechanical Defects: State whether a claim is made that there was a mechanically
defective condition or mechanical failure of the vehicle being operated by
plaintiff at the time of the collision in question which contributed to cause
the collision in question and if so, state the nature of said mechanically
defective condition of the vehicle and what actually occurred to contribute to
the cause of the accident in question.
22.
Application Statements: State whether plaintiff has made any written statements
or given information regarding plaintiff's physical condition in connection with
any application for employment or insurance since the date of the collision and
if so, please state:
(a)
The name and address of the party to whom the statement was given; and,
(b)
The date of the statement.
Right-click
here to download the foregoing interrogatories in
Microsoft Word format (select "save target as" in Internet Explorer
or "save link as" in Netscape).
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