Plaintiff’s Second Set of Interrogatories

These are follow up interrogatories to flush out what is typically foolish objections to requests for admission.

• Sample car accident interrogatories (example of the first set you should serve)

TO: Defendant
FROM: Plaintiff

COMES NOW, the Plaintiff, ____________ and propounds Interrogatories upon the Defendant, __________________, to fully, under oath, and in accordance with the Maryland Rule of Civil Procedure, Rule 2-421, subject to the instructions set forth below:

Instructions

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. Unless otherwise stated, these Interrogatories refer to the time, place, and circumstances of the occurrence mentioned or complained of in the Complaint.
3. Where name and identity of a person is required, please state full name, home address and also business address, if known.
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 attorney’s. When answer is made by corporate defendant, state the name, address and title of persons supplying the information and making the affidavit, and announce the source of his or her information.
5. The pronoun “you” refers to the party to whom the Interrogatories are addressed and the parties mentioned in clause (d).
6. “Identify” when referring to an individual, corporation, or other entity shall mean to set forth the name and telephone number, and if a corporation or other entity, its principle place of business, or if an individual, the present or last known home address, his or her job title or titles, by whom employed and address of the place of employment.

Interrogatories

1. Does the Defendant know of any person believed or understood by Defendant to have personal knowledge of the allegations as set forth in the Complaint on the damages claimed by Plaintiff?
2. Set forth all facts upon which you intend to rely to support your denial of Plaintiff’s First Set of Request for Admission, Request #12. Include in your answer the witnesses and medical records you believe support your denial and the reasonable inquiry that you made before denying this request.
3. Set forth all facts upon which you intend to rely to support your denial of Plaintiff’s First Set of Request for Admission, Request #13. Include in your answer the witnesses and medical records you believe support your denial and the reasonable inquiry that you made before denying this request.
4. You have denied that the treatment given and the bill for services rendered to Plaintiff were fair, reasonable, necessary, and causally related to the car crash complained of in the Plaintiff’s Complaint. See Plaintiff First Set of Requests for Admission, Question and Answer, #17 and #18. Set forth the reasonable inquiry that you made before denying these requests and set forth all facts upon which you intend to rely upon at trial to support your denial.
5. Do you believe that Plaintiff has been dishonest with anyone regarding the car crash and the injuries he suffered? If so, state with specificity what facts you believe he gave you that were dishonest and why you hold that opinion.
6. Your request for admissions indicate that you do not believe that “Plaintiff suffered injuries while fighting valiantly for his country in Tet Offensive in Vietnam in 1968 where suffered injuries requiring a below the knee leg amputation.” See Plaintiff’s First Set of Request for Admission, Question and Answer, #10. Set forth the reasonable inquiry that you made before denying Request for Admission #10 and set forth all facts upon which you intend to rely upon at trial to support your denial.

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

Certificate of Service

I hereby certify that a copy of the foregoing Plaintiff’s Second Set of Interrogatories has been sent via U.S. Mail, first-class, postage prepaid, on the 17th day of July, 2021__, to:

State Farm
H. Barritt Peterson, Jr.,&Associates
One W. Pennsylvania Avenue
Suite 500
Towson, Maryland 21204-5025

• Overview of these claims
• What is underinsurance and how does it work?