Interrogatories - Vehicle/Bicycle Accident

[Plaintiff to Defendant]

1. Were you driving a vehicle that was involved in a collision with a bicycle rider, on __________, __________ [North, South, East, or West] of its intersection with __________ in the city of __________? If your answer is anything other than an unqualified “No,” please set forth the following information specifically and in detail:

   1. Who was the owner of the vehicle that you were driving at the time of the subject accident? Provide his or her name, address, driver’s license and telephone number.

   2. Set forth the present location of the vehicle that you were driving and the name, address and telephone number of the person who presently has custody of it.

   3. Set forth the name and address of the liability insurance carrier that covered the vehicle that you were driving at the time of the collision. Also provide details concerning coverage, including: The policy number, policy limits, the amount of any deductibles and the status of the policy with respect to premium payments. Describe special provisions pertaining to bicyclists, if any. Also, please state whether or not you will without a motion to produce, attach a copy of the policy and declaration sheet to your answers to these interrogatories.

   4. State whether or not you are personally insured by any liability insurance carrier and if so, provide details concerning coverage, including: The policy number, policy limits, the amount of any deductibles, the status of the policy with respect to premium payments. Describe special provisions pertaining to bicyclists, if any. Also, please state whether or not you will without a motion to produce, attach a copy of the policy and declaration sheet to your answers to these interrogatories.

2. At the time of the collision, did you have a valid driver’s license? If not, please explain why. If your answer is “Yes,” please state your driver’s license number, the state of issuance, the date of issuance, the expiration date and all driving restrictions, if any; as used herein, “restrictions” would include but not be limited to matters involving hearing aids and corrective lenses.

3. Has your driver’s license ever been revoked or suspended? If your answer is anything other than an unqualified “No,” please set forth the following information specifically and in detail with respect to each revocation or suspension:

   1. The dates and periods for each revocation or suspension.

   2. The reasons for each revocation or suspension.

4. For how long a period of time had you been in your vehicle driving prior to the collision? How many miles had you driven? How many miles had you driven during the 24 hour period preceding the collision?

5. For how long a period of time had you been a passenger in any vehicle prior to the collision?

6. Please provide the following information with respect to the events immediately preceding your collision with the bicyclist:

   1. What was your purpose for driving?

   2. Where were you going?

   3. Describe the composition of the roadway [wet/dry, slippery, icy, etc.]. Also, indicate whether or not there was a bicycle or jogging lane.

   4. How fast were you going immediately prior to impact?

   5. Did you attempt to slow down prior to impact?

   6. Did you, in fact, slow down prior to impact? If so, to what speed?

   7. When you first saw the bicyclist with which you collided, how far away were you from that bicycle? How fast were you going at that time.

   8. Just prior to the collision, describe the direction and speed in which the bicyclist was traveling. Indicate whether the bicyclist was riding on the sidewalk, the roadway, or crossing an intersection.

      I. Just prior to the...