Progressive Insurance Interrogatories

Below is a draft of interrogatories that were served on us by Progressive in a motor vehicle accident case. We post this to give people a rough idea of the kind of questions Progressive is going to be asking in discovery.

1. Give a concise statement of facts as to how you contend that the occurrence took place. Provide a copy of any photographs and documents concerning this occurrence.
2. State the names and addresses and telephone numbers of all eyewitnesses and the location of each at the time of the occurrence and what it is that you believe they will be able to testify to with regard to how this incident occurred.
3. State the names and addresses of all persons who have personal knowledge of facts material to this case. State specifically what facts you believe they are aware of and will be able to testify to at the time of trial.
4. Identify all persons who have given you “statements,” as that term is defined in Rule 2-402(d), concerning the action or its subject matter. For each statement, state the date on which it was given and identify the custodian and provide a copy of same.
5. State in detail the nature of all bodily injuries allegedly sustained by the Plaintiff as a result of the occurrence, and state which injuries, if any, are claimed to be an aggravation to any condition existing prior to the occurrence and what, if any, alleged injuries are claimed to be permanent at this time.
6. State the names and addresses of all physicians or institutions which have examined you or given you medical treatment for injuries claimed as a result of the occurrence, including the dates and nature of such treatment.
7. State the names and addresses of all physicians and hospitals, which have examined and/or treated you for the past ten (10) years, and the dates and nature of such treatments. This request specifically includes names and addresses of your family doctor for the past ten years, but is not limited specifically to identification of your family doctor.
8. State the names and addresses of all persons, firms or corporations you expect to call as expert witnesses at the trial of this case (including 10-104 submissions) and state the subject matter upon which each such expert witness is expected to testify, the subject of such expert’s finding and the opinions to which the expert is expected to testify, a summary of the grounds for each such opinion, and attach to your answers to interrogatories a copy of any and all written reports made by each such expert concerning these opinions and findings.
9. If you contend that you sustained any personal injury as a result of the subject occurrence, please state in detail the nature and extent of any personal injury and the length of time during which you contend you were suffering from these alleged injuries. If you claim that your injuries are permanent, please explain in detail as to the basis of your contention.
10. Did you lose any time from employment as a result of the injuries sustained in this accident? If so, state precisely the dates of absence from employment, the amount of wages lost on account thereof, and the names and addresses of the employers from whom said wages or income would have been received, and state whether or not there is a continuing wage loss or a diminished income.
11. If you are claiming any lost wage damages as a result of this occurrence, please provide copies of your State and Federal tax returns for the three years preceding the accident up to the present date. In addition, please provide copies of any and all employment records in your possession (i.e., pay stubs, lost wage statements, etc.) that support your lost wage claim.
12. Give an itemized statement of all expenses paid or incurred by you as a result of the occurrence and provide copies of all medical records, bills, damage estimates, photographs, and any other documentation concerning expenses incurred by you as a result of this incident.
13. State specifically whether you received any injuries, in any accident or occurrence previous to the occurrence, or subsequent thereto, if so, state the details, including date, place of occurrence, nature of injuries sustained and names and addresses of the parties involved, stating the names and addresses of attending physicians and dates of all examinations or treatments for such injuries and provide copies of all medical records and bills in your possession or your attorney’s possession that may have handled any prior claims.
14. State whether you ever had, prior to the occurrence, complained of pain or symptoms of disease or injury in those parts of your body, which were injured in the occurrence. If so, state when, describe the complaints or symptoms, and state the names and addresses of all doctors or hospitals who treated or examined you for such complaints or symptoms, and the dates of such examinations or treatments and provide copies of any and all medical records in your possession concerning the above-referenced prior injuries or complaints.
15. State your date of birth, social security number, and your height and weight, both now and at the time of the occurrence. If a married woman, state your full maiden name.

Certificate of Service

I hereby certify that a copy of the foregoing Answers to Interrogatories has been sent via U.S. Mail, first-class, postage prepaid, on the day of , 2012, to:

Melissa A. Hubshman, Esq.
Law Offices of Progressive Casualty
Insurance Company
800 Red Brook Boulevard, Suite 120
Owings Mills, MD 21117

Laura G. Zois
Miller & Zois, LLC
1 South St, #2450
Baltimore, MD 21202
(410)779-4600
(410)760-8922 (fax)
Attorney for the Plaintiff

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