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Example Interrogatories for Uninsured Motorist Claim

Below are sample interrogatories that we served on GEICO in a uninsured motorist case.

Remember, insurance companies reflexively deny everything in discovery. Use this to your advantage. Without any thought whatsoever, there discovery responses will imply that your client is a malingering liar. This puts you in a great position with the jury. Why? Because when the deny everything — even the obvious that they must concede — the lose all credibility with the jury.

So when the insurance company claims in answer to interrogatories that your client – and their client – was not hurt despite a car accident that totaled her car and sent her to the emergency room, don’t argue with them.  You can read those interrogatory answers to the jury at trial.

TO: GEICO, Defendant
FROM: Plaintiff

The following Interrogatories are propounded pursuant to the Maryland Rules of Procedure and are to be answered fully and under oath:

  1. These Interrogatories are continuing in character, so as to require you to file supplementary answers if you obtain further or different information before trial.
  2. Where the name or identity of a person is requested, please state full name, home address, and also business address, if known, as well as the home and business telephone number.
  3. Unless otherwise indicated, these Interrogatories refer to the time, place, and circumstances of the auto accident mentioned or complained of in the pleadings.
  4. Where knowledge or information in possession of a party is requested, such request includes knowledge of the party’s agents, representatives, and, unless privileged, his attorneys. When answer is made by a corporation or other legal entity, state the name, address, and title of the person supplying the information, and making the affidavit, and the source of his information.
  5. Said Interrogatories shall include the following definitions:
    1. Any request to identify any record, documents, or writing shall include identification as to: (a) the date the same was dated or otherwise prepared; (b) the name, address, and title of the person preparing same; (c) the name, address, and title of the person for and to whom the same was prepared and addressed; (d) the name, address, and title of all persons to whom copies of the same were furnished or otherwise forwarded; (e) the title and other identifying designation given the same; (f) the subject matter and content of the same; and (g) the name, address, and location and title of the person having possession.
    2. The pronoun “you” refers to the party to whom these Interrogatories are addressed, its agents, servants, employees, representatives, officers, or anyone acting for or on behalf of that party.

Uninsured Motorist Cases

  1. State the name and address of any person answering these Interrogatories. Include in your answer your professional title, your affiliation with the GEICO, and the length of time with GEICO in that position.
  2. State whether there was a contract of insurance between the insurance company and the Plaintiff to provide uninsured/underinsured motorist benefits. [This is the key question. You also want to seek a stipulation of coverage for trial.)
  3. Name the eyewitnesses you are aware of that witnessed all or part of the auto accident, and state the location of each such eyewitness at the time of the auto accident.
  4. Name all persons and/or personnel who were at or near the scene, or arrived at the scene within two hours after the motor vehicle crash.
  5. If anyone investigated this matter for you, state their name(s) and address(es), and state whether such investigation was reduced to writing. If said investigator obtained any signed statements or recorded statements, identify the person who gave the statement and attach to your Answers a copy of any said statement.
  6. If you contend that the Plaintiff in this action was at all negligent in causing the collision, state the reason(s) you make this contention. Include in your answer where and from whom you obtained the information to make this contention.
  7. State whether you have within your possession or control photographs, plats or diagrams of the scene, videotapes, or objects connected with said auto accident; and if so, identify each such object, the date produced or obtained, and the present custodian thereof.
  8. State the manner in which you say the incident complained of occurred, giving the various speeds, positions, directions, and locations of all vehicles involved in the said accident.
  9. State whether you have within your possession or control, or have knowledge of, any transcripts of testimony, in any proceedings arising out of the auto accident. If so, state the date, the subject matter, the name and address of the person who has present possession of each said transcript of testimony.

Tips on Each Insurance Company

  1. Do you know of any statement, conversation, comment, or report made by this Plaintiff at the time of the auto accident or following the auto accident, concerning the auto accident or facts relevant to any issue in this case? If your answer is “yes,
    ” state the content of such statement, conversation, comment, or report, the place where it took place, and in whose presence it was made.
  2. State the name and specialty of all experts whom you propose to call as witnesses at trial, and for each expert state the subject matter on which the expert is expected to testify, the substance of the findings and opinions to which the expert is expected to testify and attach to your Answers copies of all written reports of each such expert.
  3. What investigation have you done to determine whether the driver or owner of the vehicle that was involved in the auto accident with Plaintiff was insured with liability insurance at the time of the auto accident? Include in your response, the results of that investigation and by whom it was conducted.
  4. Were there any charges placed against the uninsured driver or owner of the vehicle involved in the auto accident with Plaintiff as a result of this auto accident and if so, did they plead guilty or were they found guilty of any violation arising from the auto accident? If so, state the violation they were charged with, and where and when they pled or were found guilty.
  5. State the name of any insurance company that might be liable to satisfy all or part of any judgment that might be entered against the driver or owner of the vehicle involved in the auto accident with Plaintiff in this case, and for each company named, state the limits of coverage.
  6. State who owned the various vehicles involved in the auto accident and which parts of those vehicles were damaged in the auto accident complained of, the name and address of the person or entity who repaired each vehicle, and the date and cost of repairs. If the vehicles have not been repaired, state the present location of said vehicles, the days of the week, the time of day, and the places they may currently be seen.
  7. If you may contend that Plaintiff suffered from a pre-existing condition please state all facts upon which you rely to support your contention.
  8. If you may contend that Plaintiff aggravated a preexisting condition please state all facts upon which you rely to support your contention.
  9. If you may contend that Plaintiff’s herniated disc injury was not the result of the auto accident on November 15, 2020, please state all facts upon which you rely upon to support your contention.
  10. Please identify any experts of any kind that you have consulted with and who has rendered opinions prior to answering these interrogatories and whose opinions you have relied upon in denying this claim.

Respectfully submitted,

Miller & Zois, LLC.

Ronald V. Miller, Jr.
Laura G. Zois
1 South St, #2450
Baltimore, MD 21202
(410)779-4600
(410)760-8922 (Fax)
Attorneys for the Plaintiff


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