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X. FORMS
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SALLY MAE HARPER Plaintiff
v.
JOHN DOE CORPORATION Defendant
IN THE circuit court for Baltimore city
case no.:
TO: Sally Mae Harper, plaintiff
FROM: John Doe Corporation, defendant, which propounds the following interrogatories pursuant to Rule 2-421 of the Maryland Rules of Procedure. The interrogatories are to be read and interpreted in accordance with the definitions, and the answers are to be furnished in accordance with the instructions set forth herein.
Each subpart of an interrogatory should be separately answered. Interrogatories or subparts should not be combined for the purpose of supplying a common answer, and answers should not be supplied by reference to the answer of another interrogatory or subpart, unless the answer is completely identical to the answer referred to.
Supplemental answers, updating the answers given herein, are to be submitted periodically as additional information becomes available. Final supplementary submission shall be made no later than thirty (30) days prior to the trial of this action.
As used herein, the terms "document" or "documents" include, but are not limited to, all paper material of any kind, whether written, typed, printed, punched, filmed or marked in any way; recording tapes or wires; film, photographs, movies, or any graphic matter, however produced or reproduced; and all mechanical or electronic sound recording or transcripts thereof.
"Your" or "you" refers to the parties to whom these interrogatories are addressed, and all of their predecessors or successors, as well as their agents, employees, servants or representatives, and, unless privileged, their attorneys.
The term "person" includes a corporation, partnership, other business association or entity, a natural person and any government or governmental body, commission, board or agency.
The term "occurrence," unless otherwise indicated, refers to the time, place and circumstances of the occurrence which is complained of in the most recent statement of claim filed in this action.
The term "vehicle," unless otherwise indicated, refers to the motor vehicle about which complaint is made by you.
Where knowledge or information of or possession or control by a party is requested or inquired of, such request or inquiry includes knowledge, information, possession or control of or by the party's agents, representatives and, unless privileged, the party's attorneys.
"Identify" or "identification," when used in reference to an individual person, means to state his full name, present address, if known, and his present position and business affiliation. When used in reference to a person other than an individual person, "identify" or "identification" means to state whether such person is a corporation, partnership, or other organization, and the name, present and last known address and principal place of business. Once any person has been identified properly, it shall be sufficient thereafter when identifying that same person to state his name only.
"Identify" or identification," when used in reference to a document, means to state the date, the author, the addressee, type of document (e.g., letter, memorandum, telegram, chart, etc.) the name and address of the present custodian of all copies thereof and any other descriptive data identifying it with sufficient particularity to meet the requirements of a request for production of documents pursuant to rules of court. If any such document was, but is no longer, in the party's possession or subject to the party's control, state what disposition was made of it and the reason for such disposition. In lieu of identifying any document, a true and correct copy thereof may be annexed to and incorporated in the answers to these interrogatories.
1. Identify all experts whom you propose to call as witnesses at the trial of this case, state the subject matter on which each expert is expected to testify, the substance of the facts and opinions to which each expert is expected to testify, give a summary of the grounds for each such opinion and identify all reports, resumes and statements received from each such expert.
2. Identify all persons or entities having or claiming a subrogation interest in the outcome of this action.
3. Describe in detail any agreement, formal or informal, whether reduced to writing or not, pursuant to which the liability of any person or entity for any injuries or damages arising out of the acts or omissions described in your...
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