Personal Injury Interrogatories to Defendant

This Personal Injury Interrogatories to Defendant document sets forth many of the special interrogatories that should be propounded on a defendant in a personal injury case. Interrogatories are an integral part of conducting discovery, and this document will help ensure that no information is overlooked. The propounding party can easily insert specific terms into this document to make sure the end result is tailored to the party's unique situation. This document should be used by plaintiffs or their attorneys when conducting discovery in a personal injury case.

PROPOUNDING PARTY: ________________ [Instructions: Insert name of Plaintiff]

RESPONDING PARTY: ________________ [Instructions: Insert name of Defendant]

SET NUMBER: ________________ [Instructions: Since multiple sets of requests are permitted, the User should set forth the set number]

TO ALL PARTIES HEREIN AND THEIR RESPECTIVE ATTORNEYS OF RECORD:

PLEASE TAKE NOTICE that Plaintiff, ________________ [Instructions: Insert name of Plaintiff], hereby request that Defendant ________________ [Instructions: Insert name of Defendant] respond to the following interrogatories under oath, pursuant to ________________ [Instructions: Cite to governing law that permits the discovery demand].

DEFINITIONS

1. The term 'YOU' and 'YOUR' refers to the responding party, Defendant ________________ [Instructions: Insert name of Defendant].

2. The term 'DOCUMENT' means a writing, as defined in ________________ [Instructions: Cite to relevant evidence code section in state that sets forth definition for 'document' or set forth definition in its entirety here], and includes the original or a copy of handwriting, typewriting, printing, photostating, photographing, and every other means of recording upon any tangible thing and form of communicating or representation, including letters, words, pictures, sounds, or symbols, or combinations of them, including, but not limited to, papers, money, agreements, contracts, checks, notes, bank notes, memoranda, correspondence, letters, telegrams, statements, books, reports, studies, minutes, records, accounting books, maps, plans, drawings, diagrams, photographs, analysis, surveys, transcriptions, and recordings of which you have any knowledge or information, whether in your possession or under your control or not, relating or pertaining in any way to the subject matters in connection with which it is used, and includes, without limitation, originals, all file copies, and all other copies, no matter how or by whom prepared, and all drafts prepared in connection with such writings, whether used or not.

3. The term 'INCIDENT' refers to Plaintiff's injury at ________________ [Instructions: Insert location] on ________________ [Instructions: Insert date] as mentioned or complained of in the Complaint..

SPECIAL INTERROGATORIES:

SPECIAL INTERROGATORY NO. 1

Where was YOUR place of residence at the time of the INCIDENT?

SPECIAL INTERROGATORY NO. 2

Do you know of any person or persons that have personal knowledge of the facts related to the INCIDENT, including eyewitnesses and any individuals who arrived on the scene within 2 hours after the INCIDENT.

SPECIAL INTERROGATORY NO. 3

If YOUR response to the interrogatory No. 2 is yes, identify all DOCUMENTS which support YOUR response.

SPECIAL INTERROGATORY NO. 4

Please state how this INCIDENT took place, including ____________ [Instructions: Set forth specific information related to the cause of the injury. i.e. the date, time, and location of the accident].

SPECIAL INTERROGATORY NO. 5

Set forth the name and contact information for any person that investigated the facts related to this case for you, including, but not limited to, medical experts and private investigators. Attach any reports created from such investigation.

SPECIAL INTERROGATORY NO. 6

Describe in detail the reason that YOU were at the location of the INCIDENT on ________________ [Instructions: Insert time and date]

SPECIAL INTERROGATORY NO. 7

Identify all Documents that relate to the Plaintiff's physical condition, or the scene of the occurrence

SPECIAL INTERROGATORY NO. 8

Set forth the present custodian of each such item identified in Interrogatory no. 7.

SPECIAL INTERROGATORY NO. 9

List all insurance coverage you have related to the INCIDENT, including the name of the insurance company, the policy owner, the kind of coverage, the policy number, and the effective dates of the policy.

SPECIAL INTERROGATORY NO. 10

Identify each person who has provided you a signed statement regarding the INCIDENT or the personal injuries suffered by the Plaintiff.

SPECIAL INTERROGATORY NO. 11

If you assert that the Plaintiff acted took any action to cause or contribute to Plaintiff's personal injuries, set forth all facts upon which you base this assertion.

SPECIAL INTERROGATORY NO. 12

Please state the name, telephone number and address of the individuals who were present with YOU at the time of the incident.

SPECIAL INTERROGATORY NO. 13

Had YOU been to the location of the INCIDENT prior to ________________ [Instructions: Insert date of Incident]?

SPECIAL INTERROGATORY NO. 14

4 Please state in detail all facts supporting YOUR contention in YOUR Answer that Plaintiff ________________ [Instructions: Insert allegation in Answer].

SPECIAL INTERROGATORY NO. 15

In the past ten years, have YOU ever consumed any narcotic substance including but not limited to methamphetamine, cocaine and marijuana?

SPECIAL INTERROGATORY NO. 16

If YOUR response to the preceding Interrogatory is yes, please list all narcotic substances YOU have consumed including number of times YOU consumed them.

SPECIAL INTERROGATORY NO. 17

From ________________ [Instructions: Insert date preceding INCIDENT] to the time of the INCIDENT, did YOU ingest any non-prescription narcotics such as methamphetamine?

SPECIAL INTERROGATORY NO. 18

If YOUR response to the preceding Interrogatory is yes, please list all non-prescription narcotic substance(s) YOU ingested, including number of times YOU ingested them.

SPECIAL INTERROGATORY NO. 19

From ________________ [Instructions: Insert date preceding INCIDENT] to the time of the INCIDENT, did YOU ingest any prescribed medication?

SPECIAL INTERROGATORY NO. 20

If YOUR response to the preceding Interrogatory is yes, please list the medication(s) by name and description of the medication(s) that YOU ingested from ________________ [Instructions: Insert date preceding INCIDENT] to the time of the INCIDENT.

SPECIAL INTERROGATORY NO. 21

From ________________ [Instructions: Insert date preceding INCIDENT] to the time of the INCIDENT, did YOU ingest any non-prescription/over-the-counter medication, including but not limited to common cold medication? SPECIAL INTERROGATORY NO. 22

If YOUR response to the preceding Interrogatory is yes, please list the medication(s) by name and description of the medication(s) that YOU ingested from ________________ [Instructions: Insert date preceding INCIDENT] to the time of the INCIDENT.

SPECIAL INTERROGATORY NO. 23

Prior to INCIDENT, have YOU ever suffered from any condition or illness that caused or can cause loss of consciousness?

Dated: ________________ [Instructions: Insert date]

________________ [Instructions: Set forth name of attorney]

Attorneys for Plaintiff

________________ [Instructions: Set forth name of Plaintiff]

[Comments: User should attach a proof of service with this request for production of documents]

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