Interrogatories 4-samples Questions and Answers from Car Accident Case

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1. State the full name of the Defendant answering, as well as your current residence address, date of birth, marital status, driver's license number and issuing state, and social security number, and, if different, give the full name, as well as the current residence address, date of birth, marital status, driver's license number and issuing state, and social security number of the individual signing these answers.

ANSWER: Cortez Robinson, 8355 S. St. Lawrence, Chicago, Illinois; Date of Birth: XX/XX/69; Driver's License Number: XXXXXXXXXXXXXX IL; last four digits of Social Security Number: 1652; marital status: Single.

2. State the full name and current residence address of each person who witnessed or claims to have witnessed the occurrence that is the subject of this suit.

ANSWER: None other than the parties to the lawsuit and the individuals that may be indicated on the police report, investigation continues.

3. State the full name and current residence address of each person not named in Interrogatory No. 2 above who was present and/or claims to have been present at the scene immediately before, at the time of and/or immediately after said occurrence.

ANSWER: None at this time, investigation continues.

4. As a result of the occurrence, were you made a Defendant in any criminal or traffic case? If so, state the court, the caption, the case number, the charge or charges filed against you, and whether you pleaded guilty thereto and the final disposition.

ANSWER: No.

5. Were you the owner and/or driver of any vehicle involved in the occurrence? If so, state whether the vehicle was repaired and, if so, state when, where, by whom, and the cost of said repairs.

ANSWER: Yes; yes; 2 weeks after accident; garage; my mechanic; about $500.00.

6. Were you the owner and/or driver of any vehicle involved in said occurrence? If so, were you named or covered under any policy of liability insurance effective on the date of said occurrence and, if so, state the name of each such company, the policy number, the effective period and the maximum liability limits for each person and each occurrence, including umbrella or excess insurance coverage, property damage and medical payment coverage.

ANSWER: Yes, I am the owner, and I believe I was covered under United Auto Insurance policy number 100008445 with effective dates of 8/4/05 to 8/4/06 and limits of 20/40/15.

7. Do you have any information tending to indicate:

(a) That any plaintiff was, within the five years immediately prior to said occurrence, confined in a hospital, treated by a physician or x-rayed for any reason other than personal injury? If so, state each plaintiff so involved and give the name and address of each such hospital, physician, technician or clinic, the approximate date of such confinement or service and state, in general, the reason for such confinement or service.

(b) That any plaintiff had suffered serious personal injury prior to the date of said occurrence? If so, state each plaintiff so involved and state when, where and in general how he or she was injured and describe in general the injuries suffered.

(c) That any plaintiff has suffered either (a) any personal injury or (b) serious illness, since the date of said occurrence? If so, state each plaintiff so involved and, for (a) state when, where and in general how he or she was injured and describe in general the injuries suffered; and for (b) state when he or she was ill and describe in general the illness.

(d) That any plaintiff has ever filed any other suit for his or her own personal injuries? If so, state each plaintiff so involved and give the court in which filed, the year filed and the title and docket number of said case.

ANSWER: (a) - (d) None other than the information previously submitted by the attorney for the plaintiff.

8. Were any photographs, movies and/or videotapes taken of the scene of the occurrence or of the persons and/or vehicles involved? If so, state the date or dates on which photographs were taken, the subjects thereof and who now has custody of them, and the name, address and occupation and employer of the person taking them.

ANSWER: None at this time, investigation continues.

9. Have you (or anyone acting on your behalf) had any conversations with any person at any time with regard to the manner in which the occurrence complained of occurred, or have you overheard any statements made by any person at any time with regard to the injuries complained of by plaintiff or the manner in which the occurrence complained of occurred? If the answer to this Interrogatory is in the affirmative, state the following:

a. The date or dates of such conversations and/or statements;

b. The place of such conversations and/or statements;

c. All persons present for the conversations and/or statements;

d. The matters and things stated by the person in the conversations and/or statements; and

e. Whether the conversation was oral; written and/or recorded;

f. Who has possession of the statement if written and/or recorded.

ANSWER: None other than at the scene of the occurrence, investigation continues.

10. Do you know of any statements made by any person relating to the occurrence complained of by the plaintiff? If so, give the name and address of each such witness, the date of said statement, and state whether such statement was written and/or oral.

ANSWER: None at this time, investigation continues.

11. Had you consumed any alcoholic beverage within 12 hours immediately prior to said occurrence? If so, state the names and addresses of those from whom it was obtained, state where it was consumed, and state the particular kind and amount of alcoholic beverage so consumed by you, and state the names and current residence addresses of all persons known by you to have knowledge concerning the consumption of said alcoholic beverages.

ANSWER: No.

12. Have you ever been convicted of a misdemeanor involving dishonesty, false statement or felony? If so, state the nature thereof, the date of conviction, and the court and the caption in which the conviction occurred. For the purpose of this interrogatory, a plea of guilty shall be considered as a conviction.

ANSWER: Yes; drugs in 1992.

13. Had you used any drugs or medications within 24 hours immediately prior to said occurrence. If so, state the names and addresses of those from whom it was obtained, state where it was used, and state the particular kind and amount of drug or medication so used by you, and state the names and current residence addresses of all persons known by you to have knowledge concerning the use of said drug or medication.

ANSWER: No.

14. Were you employed on the date of the occurrence? If so, state the name and address of your employer, and the date of employment and termination, if applicable. If you answer is in the affirmative, state the position, title and nature of your occupational responsibilities with respect to your employment.

ANSWER: Yes; AOL Time Warner, 25 E. Washington, Chicago, Illinois; April 1991 - October, 2006; Sales Manager/Trainer.

15. What was the purpose and/or use for which the vehicle was being operated for at the time of said occurrence?

ANSWER: Family car.

16. State the names and addresses of all persons who have knowledge of the purpose for which the vehicle was being used for at the time of said occurrence.

ANSWER: Tamie Lamb, 7552 S. Emerald; Leesa Binion, 8037 S. Evans.

17. State the name and address of the registered owner of each vehicle involved in said occurrence.

ANSWER: See Police Report, investigation continues.

18. Have you ever had your driver's license suspended and/or revoked? If so, state whether it was suspended and/or revoked, the date it was suspended and/or revoked, the reason for the suspension and/or revocation, for what period of time was it suspended and/or revoked, and the state that issued the license.

ANSWER: No.

19. Do you have or have you had any restrictions on your driver's license? If so, state the nature of the restrictions.

ANSWER: No.

20. Do you have any medical and/or physical condition, which required a physician's report and/or letter of approval in order to drive? If so, state the nature of the medical and/or physical condition, the physician or other health care professional who issued the letter and/or report, and the names and addresses of any physician or other health care professional who treated you for this condition prior to the occurrence.

ANSWER: No.

21. State the name and address of any physician, ophthalmologist, optician or other health care professional who performed any eye examination of you within the last five years and the dates each such examination.

ANSWER: D.M.V., 99th & King Drive.

22. State the name and address of any physician or other health care professional who examined and/or treated you within the last 10 years and the reason for such examination and/or treatment.

ANSWER: Not applicable.

23. Pursuant to Illinois Supreme Court Rule 213(f), provide the name and address of each witness who will testify at trial and all other information required for each witness.

ANSWER: The parties to this lawsuit may testify as to their personal knowledge of the facts of automobile accident which forms the basis of this lawsuit including facts pertinent to liability and facts pertinent to damages claimed by the plaintiff and including any statements by the parties. The parties and the persons listed on the police report will testify to the pre-occurrence and post-occurrence facts, including but not limited to the configuration of the accident scene, the directions, and locations of the vehicles involved, speeds, times, and distances, the severity of the impact(s), the points of impact, the amount of property damage observed to the vehicles after the accident, the position of the vehicles after the accident, visual observations regarding the plaintiffs injuries and the plaintiffs complaints of injury at the scene of the occurrence; their testimony is expected to be consistent with their depositions. All other previously disclosed individuals; subject matter, liability and damages. The defendant reserves the right to disclose and call additional opinion witnesses at a later date.

24. Pursuant to Illinois Supreme Court Rule 213(g), provide the name and address of each opinin witness who will offer any testimony and state:

a. The subject matter on which the opinion witness is expected to testify;

b. The conclusions and/or opinions of the opinion witness and the basis therefore, including reports of the witness, if any;

c. The qualifications of each opinion witness, including a curriculum vitae and/or resume, if any; and

d. The identity of any written reports of the opinion witness regarding this occurrence.

ANSWER: All previously disclosed individuals regarding issues of liability and alleged injuries and damages. The parties and the individuals indicated on the police report regarding issues of liability and alleged injuries and damage; the investigating police officer regarding issues of liability and alleged injuries and damages (see police report).

25. List the names and address of all other persons (other than yourself and persons heretofore listed) who have knowledge of the facts of said occurrence and/or of the injuries and damages claimed to have resulted therefrom.

ANSWER: My attorneys.

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