Sample Interrogatories In Car Accident Lawsuits
Interrogatories are lists of questions sent to the other party during discovery to gain relevant information about your lawsuit prior to trial. You can use interrogatories to find out facts about a case, but they cannot be used for questions that draw a legal conclusion.
Here are a few sample questions to get you started with your interrogatories in a car accident case.
INTERROGATORY NO. 1: If it is your contention that you are not liable to Plaintiff, please explain in your own words the facts that support your contention. Also provide the names, addresses, and phone numbers of each and every person who can corroborate your position. Plaintiff also requests that you identify all documents that support your contention.
INTERROGATORY NO. 2: If it is your position that you are not the proper party to this cause, or if it is your position that some other corporation, entity, or person may be jointly responsible for the damages suffered by Plaintiff, whether in whole or in part, please describe in detail each and every basis for this position and identify all witnesses who you believe will corroborate this theory.
INTERROGATORY NO. 3: Please describe fully and completely, and in your own words, how the incident made the basis of this suit occur. In describing full the description of the collision. Please include the positions of all vehicles, the road, the street, the names, and block numbers or intersecting streets, the posted speed limit of each street, the speed of your vehicle immediately prior to and at the time of the collision, and the speed of any other vehicles involved in the incident.
INTERROGATORY NO. 4: State the speed of the vehicle you were occupying at 100, 50, and 20 feet prior to impact and at impact.
INTERROGATORY NO. 5: Please describe the extent of your vision just before the collision, both corrected and uncorrected, and whether you were wearing corrective lenses or dark lenses at the time of the collision.
INTERROGATORY NO. 6: If it is your position that you are not responsible for the damages sustained by the Plaintiff, please state the factual bases for your refusal to accept responsibility in this matter. In so denying the Plaintiff’s claims, please identify each and every document, fact witness, expert witness, and other discoverable items that you claim will bolster your position that you are not responsible for Plaintiff’s damages. Please be explicit.
INTERROGATORY NO. 7: If it is your position that you were not negligent, please state the facts that support your answer, identify all witnesses whom you believe will corroborate your position, and identify all documents that support your position.
INTERROGATORY NO. 8: If you have had communications with Plaintiff regarding the subject matter of this lawsuit, whether written, oral, or non-verbal, please provide the following information:
- The approximate date of the communication(s);
- The subject matter of the communication(s);
- The person(s) involved during the communication(s);
- Any other person who was present during the communication; and
- A brief summary of the communication.
INTERROGATORY NO. 9: If you had any communications with any person at the scene of the accident, please provide the following information:
- The subject of the communication.
- The person(s) involved in the communication.
- Any other person present during the communication(s); and
- A brief overview of what was said and by whom.
INTERROGATORY NO. 10: Have you ever been convicted of a felony or a crime of moral turpitude? If so, please provide the following information:
- The crime upon which you were convicted;
- The court, county, and cause number concerning the underlying conviction;
- Whether you testified at trial; and the disposition of the citation or charge.
INTERROGATORY NO. 11: If it is your position that any Plaintiff has not been damaged, please state all facts which support your position, identify all documents that support your position, and list all facts and expert witnesses who you believe will corroborate your position and a brief description of their anticipated testimony.