When a standard interrogatory uses the word: "identity," the party served with the interrogatory must identify all documents, things and persons known to that party or to that party's attorney, and the addresses of all persons identified MUST be set forth.
Where a standard interrogatory is marked with an asterisk(*), a request for production may accompany the interrogatory.
Standard Interrogatory 1. Injuries and Diseases Alleged.
State in detail the injuries or diseases that you allege that you suffered as a result of the accident referred to in the complaint.
Answer:
Standard Interrogatory 2. Medical Treatment and Reports.*
If you received medical treatment or examinations (including X-rays) because of injuries or diseases you suffered as a result of the accident, identify:
(a) Each hospital at which you were treated or examined; Answer:
(b) The dates on which each such treatment or examination at a hospital was rendered and the charges by the hospital for each; Answer:
(c) Each doctor or practitioner by whom you were treated or examined; Answer:
(d) The dates on which each such treatment or examination by a doctor or practitioner was rendered and the charges for each; Answer:
(e) All reports regarding any medical treatment or examinations, setting forth the author and date of such reports. Answer:
Standard Interrogatory 3. Other Expenses.*
If you have incurred any bills or expenses in connection with the injuries or diseases which you suffered because of the accident referred to in the complaint, and such bills or expenses are not otherwise listed in answer to these interrogatories, set forth the amount of each such bill or expense, the service for which the bill or expense was incurred, and the identity of the person who rendered the bill or who was involved in the expense.
Answer:
Standard Interrogatory 4. Prior or Subsequent Injuries or Diseases.
Either prior to or subsequent to the accident referred to in the complaint, have you ever suffered any injuries or diseases in those portions of the body claimed by you to have been affected by the accident referred to in the complaint?
Answer:
If so, identify:
(a) The injuries or diseases you suffered; Answer:
(b) The date and place of any accident, if such an injury or disease was caused by an accident; Answer:
(c) All hospitals, doctors or practitioners who rendered treatment or examinations because of any such injuries or diseases; Answer:
(d) Anyone against whom a claim was made, and the Court, term or number of any claim or lawsuit that was filed, in connection with any such injuries or diseases. Answer:
Standard Interrogatory 5. Earnings before the Accident.*
For the period of three years immediately preceding the date of the accident referred to in the complaint, state:
(a) The name and address of each of your employers or, if you were self-employed during that period, each of your business addresses and the name of the business while self-employed; Answer:
(b) The dates of commencement and termination of each of your periods of employment or self-employment; Answer:(c) A detailed description of the nature of your occupation in each employment or self-employment; Answer:(d) The amount of income from employment and self-employment for each year. (Attach your Federal income tax return for each year). Answer:
Standard Interrogatory 6. Earnings after the Accident.*
If you have engaged in one or more gainful occupations subsequent to the date of the accident referred to in the complaint, state:
(a) The name and address of each of your employers or, if you were self-employed, each of your business addresses and the name of the business while self-employed; Answer:
(b) The dates of commencement and termination of each of your periods of employment or self-employment; Answer:
(c) A detailed description of the nature of your occupation in each employment or self-employment; Answer:(d) The wage, salary or rate of earnings received by you in each employment or self-employment. (Attach your Federal income tax return for each year subsequent to the accident); Answer:
(e) The dates of all absences from your occupation resulting from the injuries and diseases suffered in this accident. Set forth the amount of any earnings or other benefits lost by you because of such absences. Answer:
Standard Interrogatory 7. Limitation of Duties and Activities after the Accident.
State whether, as a result of this accident, you have been unable to perform any of your customary occupational duties or social or other activities in the same manner as prior to the accident, stating withparticularity (a) the duties and/or activities you have been unable to perform, (b) the periods of time you have been unable to perform, and (c) the names and last known addresses of all persons having knowledge thereof.
Answer:
Standard Interrogatory 8. Witnesses and Those with Knowledge of the Accident.
(a) Identify each person who (1) was a witness to the accident through sight or hearing and/or (2) has knowledge of facts concerning the happening of the accident or conditions or circumstances at the scene of the accident prior to, after, or at the time of the accident. Answer:
(b) With respect to each person identified in the answer to the interrogatory above, state that person's exact location and activity at the time of the accident. Answer:
Standard Interrogatory 9. Statements.
Have you or anyone acting on your behalf obtained from any person any statement (as defined by the Rules of Civil Procedure) concerning this action or its subject matter?
Answer:
If so, identify:
(a) Each such person; Answer:(b) When, where, by whom and to whom each statement was made, and whether it was reduced to writing or otherwise recorded; Answer:
(c) Any person who has custody of any such statements that were reduced to writing or otherwise recorded. Answer: Standard Interrogatory 10. Statements Made by Party to Whom Interrogatory is Addressed.*
Have you given any statement (as defined by the Rules of Civil Procedure) concerning this action or its subject matter?
Answer:
If so, identify:
(a) Each person to whom a statement was given; Answer:
(b) When and where each statement was given; Answer:
(c) Any person who has custody of any such statements that were reduced to writing or otherwise recorded. Answer:
Standard Interrogatory 11. Demonstrative Evidence.*
Do you or anyone acting on your behalf know of the existence of any photographs, motion pictures, video recordings, maps, diagrams or models of the site of the accident, the parties or any other subject matter involved in this action?
Answer:
If the answer is in the affirmative, identify:
(a) The date(s) when they were made and what they are; Answer:
(b) The name and address of the person making them; Answer:
(c) The subject that each represents or portrays. Answer:
Standard Interrogatory 12. Trial Preparation Material.
Have you or anyone on your behalf conducted any investigations of the accident which is the subject matter of the complaint?
Answer:
If the answer is in the affirmative, identify:
(a) Each person, and the employer of each person, who conducted any investigations; Answer:
(b) The dates of the investigations; Answer:
(c) All notes, reports or other documents prepared during or as a result of the investigations and the identity of the persons who have possession thereof. Answer:
Standard Interrogatory 13. Experts.*
(a) State the name and address of each person whom you expect to call as an expert witness at trial and state the subject matter on which the expert is expected to testify. Answer:
(b) For each such expert, have the expert state the substance of the facts and opinions to which the expert is expected to testify and summarize the grounds for each such opinion. Answer:
(c) Set forth the qualifications of each expert, listing the schools attended, years of attendance, degrees received, and experience in any particular field of specialization or expertise. Answer:
Standard Interrogatory 14. Insurance.
(a) State whether you are covered by any type of insurance, including any excess or umbrella insurance, in connection with this accident. Answer:
If the answer is affirmative, state the following with respect to each policy:
(b) The name of the insurance carrier which issued each policy of insurance; Answer:
(c) The named insured under each policy and the policy number; Answer:
(d) The type of each policy and the effective dates; Answer:(e) The amount of coverage provided for injury to each person, for each occurrence, and in the aggregate for each policy; Answer:
(f) Each exclusion, if any, in the policy which is applicable to any claim thereunder and the reasons why you or the company claims the exclusion is applicable; Answer:
(g) Whether you have made a claim under the policy and if so, set forth the nature of the claim, the amount recovered and the date of recovery. Answer: