FORM INTERROGATORIES - PERSONAL INJURY

Instructions

1. Answer each interrogatory separately and fully in writing under oath.
2. If you cannot answer fully, state the reasons and answer to the extent possible.
3. If you object, state the grounds and answer the non-objectionable portion.

Definitions

• "Incident" means the event described in the complaint.
• "Person" includes individuals, corporations, partnerships, and government entities.
• "Document" includes emails, texts, photographs, recordings, and paper records.

Interrogatories

1. Identify your full name, address, date of birth, and phone number.
2. Identify all persons with knowledge of the Incident, including contact information.
3. State the date, time, and location of the Incident.
4. Describe in detail how the Incident occurred.
5. Identify all vehicles, equipment, or premises involved in the Incident.
6. Identify any statements you or others made about the Incident and when they were made.
7. Identify all injuries you claim resulted from the Incident.
8. Identify all healthcare providers who treated you for the injuries, including dates of treatment.
9. State the total amount of medical expenses incurred to date.
10. Identify any future medical treatment you contend is necessary and the estimated cost.
11. State the amount of lost wages you claim and identify your employer(s).
12. Identify any prior injuries or conditions to the same body parts.
13. Identify all health insurance, Medicare, Medicaid, or other benefits that paid medical bills.
14. Identify any liens or subrogation claims related to your injuries.
15. Identify all photographs, videos, or recordings relating to the Incident or injuries.
16. State whether you contend any party violated a statute or regulation and identify it.
17. Identify any witnesses who observed the Incident or its aftermath.
18. State the damages you claim for pain, suffering, and emotional distress.
19. Identify any social media posts, blogs, or online statements about the Incident or injuries.
20. Identify all experts you intend to call and the subject of their testimony.

Verification

text
I declare under penalty of perjury that the foregoing answers are true and correct.

______________________________
[RESPONDING PARTY NAME]
Date: [DATE]