Interrogatories to the plaintiff

Lawyers investigate things about a lawsuit in a variety of ways. One of these is the pre-trial phase of a lawsuit called “discovery.” In discovery, lawyers can request documents and other evidence from the other parties. One of the typical discovery methods is a set of interrogatories, which is a list of questions to the other side.

The following sample interrogatories shows an example of interrogatories that the defense lawyer might send to your personal injury lawyer for you to answer with regard to your car accident lawsuit.

Sample interrogatories to the plaintiff

1. State your correct legal name, address, marital status, age, social security number and occupation both now and at the time of the accident. Also, provide any other names or aliases by which you have been known.

2. List the names and addresses of all witnesses or persons believed or known by you to have any knowledge concerning facts about the accident.

3. List:

(a) the names and addresses of those persons who have given to you, your attorney or any person, firm or corporation acting in your behalf, any statements, accident reports, voice recordings, medical proof of claim forms, reports or memoranda in any way concerning this accident;
(b) the date of each such statement, accident report, voice recording, medical proof of claim form, report or memorandum; and
(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 to, or reasonably believed by you, your agents, 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 accident.

5. Did you give a statement or accident report to any person, firm or corporation regarding this accident? 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; and
(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, list:

(a) the date of each such conviction or plea;
(b) the court, city and state of each such conviction or plea;
(c) the nature of the offense; and
(d) the disposition of the 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 is expected to testify,
(b) the substance of the facts and opinions to which he is expected to testify, and
(c) a summary of the grounds for each opinion to which he will testify.

8. Identify all other experts consulted or engaged by you, your attorney or your agents.

9. When you first saw the defendant's vehicle, how far was your vehicle from the point of impact with the defendant's vehicle?

10. When you first saw the defendant's vehicle, how far was your vehicle from the defendant's vehicle?

11. When you first saw the defendant's vehicle, how far was the defendant's vehicle from the point of impact with your vehicle?

12. State the exact or approximate speed of the defendant's vehicle when you first saw it and also at the time of impact.

13. Describe in detail every action you took, from the time you first observed the defendant's vehicle up to the time of the impact, giving speed and direction of your course of travel.

14. State the exact or approximate speed of your vehicle at the time you first saw the defendant's vehicle and also at the point of impact.

15. Did you apply your brakes at any time just before impact with the defendant's vehicle? If so, specify:

(a) the speed (in miles per hour) of your vehicle at the time you applied the brakes;
(b) the distance in feet of your vehicle from the point of impact at the time you applied the brakes; and
(c) at the time you applied your brakes, the distance in feet of your vehicle from where it came to a complete stop after the accident.

16. Describe the positions of your vehicle and the defendant's vehicle at the moment of impact, giving distances to curblines or other fixed objects.

17. State the speed (in miles per hour) of your vehicle at the instant of impact.

18. State the purpose of your trip at the time of the accident.

19. Describe in detail the weather and road conditions at the time and location of the accident.

20. State the facts upon which you rely to support your contention that the defendant was not in the exercise of due care.

21. Describe in detail how the accident occurred, giving all facts concerning the details of the events before, at the time of, and/or after the accident, which you believe had any bearing on the accident.

22. If there were any tire or other marks on the road as a result of the accident:

(a) describe such marks;
(b) give details on length, size and location on the road surface;
(c) specify relation to each vehicle after it came to rest; and
(d) describe how and by which vehicle each such mark was made.

23. State whether, at the moment of impact, defendant's vehicle was moving or standing still, and, if it was standing still, for how long a period of time it had been standing still.

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

25. Did someone examine your vehicle to determine the extent of the damage thereto, and if so, state:

(a) the date such examination was made;
(b) the name, address and occupation of the person or persons making such examination; and
(c) the name and address of the person now in possession and custody of the records of such examination and any estimate of damages.

26. Do you or your attorneys, agents, servants or employees have any letters, statements, accident report forms or voice recordings concerning this accident which were made by the defendant? If so, give:

(a) the nature of same;
(b) the date each was taken;
(c) the name, address and occupation of the person taking same; and
(d) the name and address of the person, firm or corporation currently having possession of same.

27. Describe the exact points of contact between all vehicles involved in the accident and the order of contact, if known.

28. If the view of any driver involved in the accident was obstructed as he approached the scene of the accident, describe:

(a) each obstruction in detail,
(b) the location of each obstruction in relation to the accident, and (c) which driver was affected by each.

29. State whether you consumed any alcohol within 24 hours before the accident; if so, specify:

(a) the type or nature of beverage or beverages consumed;
(b) the quantity of each;
(c) the time and place where the beverage was consumed; and
(d) the identity and location of each person present when the beverage was consumed.

30. State whether you took any drugs or narcotics (including prescription drugs) within twenty-four (24) hours before the accident, and if so, specify:

(a) the type of each such drug,
(b) the quantity of each,
(c) the time and place each such drug was taken,
(d) the identity and location of each person present when each such drug was taken,
(e) the name and address of any person who prescribed such medication, drug or narcotic.
(f) if you did not take any drugs, were you under doctor's orders to take drugs at the time of the accident; and
(g) describe any drugs you should have taken, the reasons they were prescribed for you, and the reasons that you did not take them.

31. State whether you were acting within the scope of your employment or were acting as an agent at the time of the accident and, if so, list:

(a) the name and address of your employer or principal,
(b) your position with the employer or principal, and
(c) the exact nature of your duties at the time of the accident.

32. Identify the contents of any insurance agreement under which any person may be liable to satisfy part or all of a judgment which may be entered against you in the action, or to indemnify or reimburse you for payments made to satisfy any such judgment, including, without limitation: the limits of any policies, which policies are primary, which are excessive, and whether you have received any reservation of rights letter from any applicable carriers in response to your request for coverage or a defense.

33. Describe the nature, extent, and location of all injuries you allege you suffered as a result of the accident, and which of those injuries you allege are permanent.

34. List:

(a) the name and address of each doctor or other health care provider who has treated you for the alleged injuries,
(b) the date of each treatment, and
(c) the nature of each treatment; give an itemized statement of the charges for each treatment.

35. If you received treatment at a hospital or hospitals, specify:

(a) the treatment, and the place and dates of such;
(b) whether you received in-patient or out-patient treatment; and
(c) an itemized statement of the expenses incurred for such treatments.

36. If you, or any representative of yours, at any time received any medical or X-ray reports from any hospitals or physicians reporting on the injuries sustained in the accident, state:

(a) whether and from whom you or your representative received any such reports and
(b) the name and address of the person currently in possession or custody thereof

37. If you were employed or self-employed at the time of the accident, describe:

(a) the nature of such employment and the length of time so employed,
(b) the name and address of your employer (if applicable),
(c) your average weekly or monthly earnings at the time of the accident,
(d) the period of time (inclusive dates) during which you allege you were prevented from carrying on your usual occupation, and
(e) your actual total loss of earnings in dollars.

38. If you have received any money or any benefits under a workers' compensation act in full or partial settlement of any claim arising out of the accident from any person, firm, or company, specify:

(a) the name and address of the person, firm, or company from whom you received such benefits;
(b) the date on which you received such benefits;
(c) the amount of benefits received; and
(d) whether you are willing to produce, upon the plaintiff's request, a copy of any document(s) which you submitted to the person, firm, or company from whom you received such benefits and a copy of any agreement, covenant, release, or discharge that may be in existence.

39. Before or after the accident, if you have had any injury, disease, or abnormality of a similar kind to the one you allege as a result of the accident and for which you sought medical attention, list:

(a) the time and place of any occurrence;
(b) the nature and date of each such injury, disease or abnormality;
(c) the names and addresses of all hospitals, doctors or other health care providers who treated you for each such injury, disease or abnormality;
(d) the dates of such treatments; and
(e) the names and addresses of any and all persons against whom any claim was made or action commenced (giving the name and location of any applicable court or commission) as a result of each such injury, disease or abnormality.

40. At any time since the accident, were any photographs or motion picture films taken of you, the scene of the accident, or the motor vehicles involved? If so, identify them by giving:

(a) the date or dates when such photographs or motion picture films were taken, and
(b) the name and address of the person or persons having possession of them.

41. Describe your vehicle:

(a) the alleged damage to the vehicle;
(b) its make, model, year, and mileage at the time of the accident;
(c) its value immediately before and immediately after the accident;
(d) the course of repair of such damages; and
(e) if an estimate of the cost of repair was made, the name and address of the person or persons who made the estimate and the date on which such estimate was made.