The topic of this video is what our interrogatories in a personal injury case. So if you have filed a lawsuit for a personal injury case, you, your lawyer may have sent out interrogatories and you may have received interrogatories and basically, all they are are questions that you are supposed to answer under oath. They’re just written question and answers. They’re relatively straightforward and this is an informational gathering process that the lawyers do in anticipation of the next step in the of the of the lawsuit it’s normally done very early on and it asks just general questions about the case. So what I’ve actually done is I’ve pulled one of the interrogatories that my client received a in a from an insurance defense lawyer again who was representing one of the big insurance companies and I just wanted to use it as an example of the types of questions that they ask and interrogatories.
Now normally once we get one of these, our client will come in, we’ll meet with the paralegal and then I’ll go through to make sure that all of the answers are correct and then we send them out. But it really is important that these interrogatories are accurate because the defense lawyer then after they received the answers, they use those to ask you questions at the deposition. If your answers change, right, that doesn’t look good for your case. And again, they use that against you then at trial. So you could have answering in an interrogatory answer in deposition and then whatever your answer is at trial and they bring up those inconsistency. So it’s a, I really take my time with these interrogatories. I try to make sure that every little piece of information is accurate because you just have to anticipate that it will be used against you.
So to get back to the inner rogatory is, I’m just going to read, um, read off the list. Uh, in a personal injury case, you’re allowed 30 interrogatories. So 30 questions. All right. So question number one, what is the name and address of the person answering these interrogatories? Number two, list all former names. And when you are known by the name State all addresses where you’ve lived for the past 10 years, the day to have lived at each address, your social security number, date of birth, driver’s license, educational background, if you’ve ever been married, the name of your spouse. Number three do you wear glasses, contact lenses or hearing aids? If so, who prescribed them? When were they prescribed? When were your eyes or ears last examined and what is the name and address of the examiner? Number four did you consume any alcoholic beverages or take any drugs or medication within 12 hours before the time of the incident described in the complaint?
If so, state the type and amount of alcoholic beverages, drugs or medication which were consumed and when and where you consume them. Number five, have you ever been convicted of a crime other than a juvenile adjudication, which under the law under which you were convicted was punishable by death or imprisonment in excess of one year or that involves dishonesty or false statement? If so, state the specific crime, the date and place of each can sick each conviction. Number six were you suffering from any physical, infirmity, disability or sickness at the time of the incident described in the complaint? If so, state it. Number seven I’m going to paraphrase some of these because it’s getting long a number seven describe in detail how the accident described in the complaint happened, including all actions taken by you to prevent the incident. Number eight describe in detail each act or admission on the part of any party to this lawsuit that you contend constituted negligence that was a contributing cause of the incident.
Number nine, were you charged with any violation of the law arising out of the incident? Number 10 where are you wearing a seatbelt? Number 11 was there a defect in your motor vehicle? Number 12 a list each item of expense or damage related to the accident. Number 13 they want to know, uh, employment rates of pay in all employers for the past 10 years. Number 14 your insurance health insurance carriers. Number 15 has anything been paid or is anything payable from a third party for the damages listed in the interrogatories? Number 16 describe each injury in which you are claiming damages in this case. That’s a big one. Number 17 list the names, addresses, and um, businesses of each physician who has treated or examined you for the injuries for which you seek damages in this case. Number 18, they ask for then all of the physicians, medical facilities that you have treated for the past 10 years and why you were there.
Number 19 list the names and addresses of all people that you believe have knowledge of the issues in the lawsuit. Number 20 do you know about any statement or remark made on behalf of any party to this lawsuit? Number 21 state the name, address of every person known to you who has knowledge about or possession, custody or control of any model. Plat, map, drawing, motion, picture, videotape or photograph. Number 21 do intend to call any expert witnesses, uh, that she has a 22. If I didn’t say that. Number 23 have you made an agreement with anyone that would limit the party’s liability? Number 24, uh, have you ever been a party in a lawsuit before? Number 25 are you currently being treated by a physician? Number 26 to you ever suffered from psychological or emotional illness or distress? Number 27 have you ever been treated for alcoholism or drug dependency?
I don’t know what that would have to do with an auto accident case, but they asked it. Number 28 if the alleged injury or injuries sustained in the accident prevent you or make you more difficult to perform your work or inhibit your daily activities, please state. And then number 29 is the last one. If you have received a surgical recommendation or have undergone a surgical procedure relating to any of your claimed injuries for priests, please provide all the details about it. So in any event, if you are wondering what interrogatories where there you go, uh, right in black and white, right out of a case with a major insurance company, insurance defense firm. Like I said, they may not all be exact. Uh, the language in every insurance defense firm may vary slightly, but they’re all, they all hit on these general areas in, uh, in that document. I just read to yourself. Hopefully, that helps and answers the questions about what an interrogatory is for a personal injury case.
*The above has been transcribed by a third party service and has not been checked for accuracy
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