Interrogatories - Vehicular Negligence

General

1. Were you driving a vehicle that was involved in a collision that occurred 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 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 with respect to single and multiple accidents, the amount of any deductibles and the status of the policy with respect to premium payments. Also, please state whether or not you will, without a motion to produce, attach a copy of the 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 with respect to single and multiple accidents, the amount of any deductibles, the status of the policy with respect to premium payments. Also, please state whether or not you will, without a motion to produce, attach a copy of the declaration sheet and policy to your answers to these interrogatories.

2. At the time of the accident, 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 Has your driver’s license ever been revoked or suspended?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 a vehicle prior to the collision?

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

   1. What was your purpose for driving? Where were you going?

   2. Describe the composition of the roadway [Wet/dry, slippery, icy, etc.].

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

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

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

   6. When you first saw the vehicle with which you collided, how far away were you from that vehicle? How fast were you going at that time.¹

   7. What, if anything, did you do or attempt to do immediately prior to impact?

   8. What was your speed at the point of impact?

      1. Did you press your brakes immediately prior to impact?

   10. Did you sound your horn immediately prior to impact?

7. Within one minute prior to the collision, state whether or not you were involved in any diversion or distraction. If so, please provide details. Also, if you removed your hands from the steering wheel of your automobile, please state the reasons for the removal and the length of time that your hands were removed.²

8. Describe in your own words, in full detail, how the accident occurred, including the events leading up to and including the collision.

9. Please set forth the name, address, telephone number, occupation, and relationship to the parties, if any, of each person who observed or witnessed the collision; also indicate where that person was located at the time of the collision.

10. Did you or anyone acting on your behalf obtain any written statements pertaining to the collision? If your answer is anything other than an unqualified “No,” then for each statement, please provide the following information:

    1. The name, address and relationship to the parties of the person who provided the statement.

    2. The availability of the person to provide additional statements.

11. Are you aware of any photographs, films, videotapes or test results pertaining to the collision? If so, please identify each such item by providing a description, the relevant date or dates that the evidence came into being, along with the name and address of the person who created the item and the name and address of the person who currently possesses it.

12. Do you contend that the fault of the collision was attributed, in whole or in part, to someone or something other than yourself? If so, please explain the basis for this claim in detail.

13. Within a period of 24 hours preceding the collision, did you consume any alcoholic beverages? If your answer is anything other than an unqualified “No,” please set forth the following information specifically and in detail for each beverage:

    1. The type of beverage consumed and the place where it was consumed.

    2. The amount consumed.

    3. The time that it was consumed.

    4. The name or other means of identification, address and telephone of each person who was present at the time of the consumption.

14. Within a period of 24 hours preceding the collision, did you consume or take any non-prescription drugs? If your answer is anything other than an unqualified “No,” please set forth the following information specifically and in detail for each dose:

    1. The type of drug consumed and the place where it was consumed.

    2. The amount consumed.

    3. The time it was consumed and the period of time within which it was consumed.

    4. The name or other means of identification, address and telephone of each person who was present at the time of the consumption.

15. Within a period of 24 hours preceding the collision, did you take or ingest any medication or prescription drugs? If your answer is anything other than an unqualified “No,” please set forth the following information specifically and in detail for each dose:

    1. The type of medication or drug consumed and the place where it was consumed.

    2. The quantity of the medication or drug consumed.

    3. The time it was consumed and the period of time within which it was consumed.

    4. The name [or other...