State Farm Interrogatories

Below are sample interrogatories that are typical from State Farm in a car accident claim.

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Sample Interrogatories From State Farm

Interrogatory No. 1: State your full name, address, date of birth, marital status, and Social Security Number.

Interrogatory No. 2: State the full name and last known address of every person known to you or to your attorneys who was an eyewitness to all or any part of the occurrence referred to in the Complaint and state their location at the time.

Interrogatory No. 4: State the full name and last known address of every person known to you who has any personal knowledge of this car accident. .

Interrogatory No. 5: Describe in detail the facts as to how you contend that the occurrence took place, including a description of the respective speeds, directions, and movement of any vehicles involved, just before, during, and after the occurrence.

Interrogatory No. 6: Give a detailed statement of all facts upon which you rely to show that the Defendant was negligent.

Interrogatory No. 7: State the names and addresses of all persons known to you or to your attorneys who have given signed or recorded statements relative to all or any part of the occurrence and state the date the signed or recorded statement was given, to whom it was given and the present custodian of each such signed or recorded statement. Attach hereto a copy of all signed statements made by the party propounding these Interrogatories.

Interrogatory No. 8: If you know of the existence of any pictures, diagrams, or objects (real evidence) relative to the occurrence or its consequences, state the nature, subject matter, date produced or obtained, and the name and address of the present custodian of each.

Interrogatory No. 9: If you contend that any document, letter, report, writing or any written instrument of any type or description is relevant to any issue in this case, identify each such written instrument, including the date and identity of the person preparing or signing such written instrument.

Interrogatory No. 10: State whether you have ever been convicted of any crimes other than for violations of the Motor Vehicle Laws, and if so, set forth the nature of such crimes, the dates of each conviction, and the name and address of the Court wherein each conviction occurred.

Interrogatory No. 11: If you consumed any alcoholic beverages of any type, or any sedative, tranquilizer or another drug, medicine or pill during the 48 hours immediately preceding the incident referred to in the Complaint, state the nature, amount, and type of item consumed, the amount of time over which each was consumed and the names and addresses of any and all persons who have any knowledge as to the consumption of these items.

Interrogatory No. 12: State whether you have within your control or have knowledge of any transcripts of testimony in any proceeding arising out of the occurrence. If so, state the date, the subject matter, the name and business address of the person recording said testimony and the name and address of the person who has possession of each such transcript of testimony.

Interrogatory No. 13: If you contend that the party propounding these Interrogatories at any time made an admission against interest with respect to any issue involved in this litigation, state the date and place and in whose presence the admission against interest was made and the nature thereof.

Interrogatory No. 14: Name all experts whom you propose to call as witnesses and attach copies of all written reports made to you by any such experts; and if no such report has been prepared, state in detail the substance of the expert’s testimony, and in any event, state the expert’s area of expertise.

Interrogatory No. 15: State with precision the nature and location of bodily injuries suffered by you, and if you have any complaints on account of injuries received in the occurrence, state in detail the nature of such present complaints.

Interrogatory No. 16: State which of your injuries, if any, you contend are permanent.

Interrogatory No. 17: Name all hospitals and physicians or any other persons or institutions who have examined or treated you due to the occurrence for which this suit has been brought and state the dates and nature of such examinations and treatments.

Interrogatory No. 18: If you have ever suffered any injuries in any accident, either prior or after the incident referred to in the Complaint, state the date and place of such injury, a detailed description of all the injuries you received, the names and addresses of any hospitals, physicians, surgeons, osteopaths, chiropractors or other medical practitioners rendering treatment, the nature and extent of recovery, and, if any permanent disability was suffered, the nature and extent of the permanent disability and if you were compensated in any manner for any injury, state the names and addresses of each and every persons or organization paying such compensation and the amount thereof.

Interrogatory No. 19: If you have ever had any serious illness, sickness, disease, or surgical operations, either before or after the occurrence referred to in the Complaint, state the date, a detailed description of your symptoms, the names and addresses of all physicians, surgeons, osteopaths, chiropractors, medical practitioners and hospitals rendering treatment (including therein insurance policies under which payment for treatment was sought and patient identifying insurance numbers), the date your condition became stationary and a description of your condition at that time.

Interrogatory No. 20: If you contend that a previous injury or condition was aggravated by the occurrence for which this suit has been brought, describe such previous injury or condition and give the names and addresses of all persons or institutions who treated or examined you for the previous injury or condition and the approximate dates of such treatments or examinations.

Interrogatory No. 21: If you were an insured (or beneficiary) under any policy of insurance under which you received benefits or reimbursement for medical expenses or any other losses resulting from the occurrence referred to in the Complaint, state the name and address of the company paying the benefits and whether the company required you to assign to it any rights of recovery you may have against others.

Interrogatory No. 22: With respect to each of the past five (5) years, state your yearly gross income and yearly net income as reported on your Federal Income Tax Returns and state the name and address of the person, firm, or corporation having custody of any papers about your income.

Interrogatory No. 23: Concerning each of the past ten (10) years, and at the present time, state the names and addresses of each of your employers, the dates of commencement and termination of each employment, a detailed description of the work performed for each employment and your average weekly wages or earnings from each employment.

Interrogatory No. 24: If you have lost any time from your employment, business, or occupation since the car accident, state the cause of such loss of time, the date of such loss of time, and the amount of wages or income lost.

Interrogatory No. 25: Itemize the expenses you made or incurred in the past or expect to incur in the future due to the occurrence.

Interrogatory No. 26: If any persons named in response to the preceding Interrogatories are known or related to you or each other, state the nature of such acquaintanceship or relationship.

Interrogatory No. 27: Name any person, not previously mentioned, with personal knowledge of facts to this case.

What Interrogatories from State Farm Are All About

Interrogatories from State Farm, like any insurance company, are written questions directed to a party in a lawsuit for which the responding party must provide answers under oath.

Interrogatories are one piece of the discovery process, the pre-trial phase in a lawsuit where each party can obtain evidence from the opposing party.  It is after this phase that most State Farm lawsuits settle.

When State Farm sends interrogatories, it typically aims to gather detailed information about an insurance claim or lawsuit involving auto accidents, homeowners claims, or other insurance disputes. The questions may seek information about the incident, the damages or injuries claimed, the claimant’s medical history, or other relevant details that would help State Farm assess the claim or prepare for defense in litigation.

Here are some general points about interrogatories from insurance companies like State Farm:

1. Purpose: The primary purpose is to collect factual information to understand the claimant’s position and the specifics of the claim or incident. Your demand letter was your ambassador; State Farm wants to know who you really are and it wants to know your weaknesses.  So they will ask details about the incident, the nature and extent of injuries or damages, prior medical conditions, your personal life, and the losses you claim.  State Farm wants these answers for two reasons: (1) to use against you at trial and (2) to evaluate the claim for settlement.
2. Formal Process: Responding to interrogatories is a formal process governed by court rules. The responses must be written, signed, and usually sworn to before a notary public.
3. Limited Number: Court rules often limit the number of interrogatories that can be asked, though the exact number can vary by jurisdiction, although most courts will allow parties to ask more than the limit if they ask.  Does this happen often in an auto tort claim against a State Farm insured?  No. State Farm lawyers do not have the time to dedicate to an individual case.
4. Deadline for Responses: There is typically a deadline by which interrogatories must be answered, often 30 days from when they were served, but this can vary depending on the court’s rules.
5. Consequences of Non-Compliance: Failing to respond to interrogatories adequately can lead to legal penalties, including sanctions from the court or being compelled to provide the requested information.  State Farm is not great about pressing for better answers to interrogatories until it is too late.

• Sample Discovery
• Sample Interrogatories
• Example Cross Examination of Frequent Flyer State Farm IME Doctor (trial transcript)