Discovery Interrogatories in Maryland Personal Injury

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DISCOVERY INTERROGATORIES

RULE 2-421. INTERROGATORIES TO PARTIES

(a) Availability; Number. Any party may serve written interrogatories directed to any other party. Unless the court orders otherwise, a party may serve one or more sets having a cumulative total of not more than 30 interrogatories to be answered by the same party. Interrogatories, however grouped, combined, or arranged and even though subsidiary or incidental to or dependent upon other interrogatories, shall be counted separately. Each form interrogatory contained in the Appendix to these Rules shall count as a single interrogatory.

(b) Response. The party to whom the interrogatories are directed shall serve a response within 30 days after service of the interrogatories or within 15 days after the date on which that party's initial pleading or motion is required, whichever is later. The response shall answer each interrogatory separately and fully in writing under oath, or shall state fully the grounds for refusal to answer any interrogatory. The response shall set forth each interrogatory followed by its answer. An answer shall include all information available to the party directly or through agents, representatives, or attorneys. The response shall be signed by the party making it.

(c) Option to Produce Business Records. When (1) the answer to an interrogatory may be derived or ascertained from the business records of the party upon whom the interrogatory has been served or from an examination, audit, or inspection of those business records or a compilation, abstract, or summary of them, and (2) the burden of deriving or ascertaining the answer is substantially the same for the party serving the interrogatory as for the party served, and (3) the party upon whom the interrogatory has been served has not already derived or ascertained the information requested, it is a sufficient answer to the interrogatory to specify the records from which the answer may be derived or ascertained and to afford to the party serving the interrogatory reasonable opportunity to examine, audit, or inspect the records and to make copies, compilations, abstracts, or summaries. A specification shall be in sufficient detail to permit the interrogating party to locate and to identify, as readily as can the party served, the records from which the answer may be ascertained.

(d) Use. Answers to interrogatories may be used at the trial or a hearing to the extent permitted by the rules of evidence.

Pattern Interrogatories under the Maryland Rules

FORM NO. 7--MOTOR VEHICLE TORT INTERROGATORIES

Interrogatories
1. Identify yourself and state all names by which you have been known, your date of birth, your marital status, and the identity of your spouse. (Standard Motor Vehicle Tort Interrogatory No. 1.)

2. State all addresses at which you have resided for the past five years and the dates that you resided at each. (Standard Motor Tort Interrogatory No. 2.)

3. Describe in detail how the occurrence took place. (Standard Motor Vehicle Tort Interrogatory No. 3.)

4. Identify all persons who were witnesses to the occurrence and state their location at the time of the occurrence. (Standard Motor Vehicle Tort Interrogatory No. 4.)

5. Identify all persons who were at or near the scene at the time of the occurrence. (Standard Motor Vehicle Tort Interrogatory No. 5.)

6. If you were in a vehicle at the time of the occurrence, identify all other persons who were in that vehicle. (Standard Motor Vehicle Tort Interrogatory No. 6.)

7. Identify all persons who arrived at the scene within two hours after the occurrence. (Standard Motor Vehicle Tort Interrogatory No. 7.)

8. If you were in a vehicle at the time of the occurrence, state the itinerary of the vehicle, including the time and place of the beginning of the trip, the time and duration of each stop, the destination, and the expected time of arrival. (Standard Motor Vehicle Tort Interrogatory No. 8.)

9. If you were engaged in any activity for an employer or other person at the time of the occurrence, state the nature of the activity and identify the employer or other person. (Standard Motor Vehicle Tort Interrogatory No. 9.)

10. If a report with respect to the occurrence was made in the ordinary course of business, state the date on which the report was made, the identity of the person who made the report, and whether the report was written, oral, or in some other form. Identify each document containing information concerning the report and the custodian of the document. (Standard Motor Vehicle Tort Interrogatory No. 10.)

11. Identify all photographs, videotapes, plats, diagrams, or other depictions of the scene or of things connected with the occurrence that are in your possession. (Standard Motor Vehicle Tort Interrogatory No. 11.)

12. Identify all persons who have given you "statements," as that term is defined in Rule 2-402 (e), concerning the action or its subject matter. For each statement, state the date on which it was given and identify the custodian. (Standard Motor Vehicle Tort Interrogatory No. 12.)

13. If you were charged with any offenses arising out of the occurrence, state the nature of the charges, the court and case number, and the disposition of the charges. (Standard Motor Vehicle Tort Interrogatory No. 13.)

14. If you contend that any party to this action caused or contributed to the occurrence, state concisely the facts on which you rely. (Standard Motor Vehicle Tort Interrogatory No. 14.)

15. If you contend that a person not a party to this action caused or contributed to the occurrence, identify each such person and state concisely the facts upon which you rely. (Standard Motor Vehicle Tort Interrogatory No. 15.)

16. If you owned or were in a vehicle damaged as a result of the occurrence, describe any damage to the vehicle. If the vehicle was repaired, identify the person who performed the repairs, the dates of the repairs, and the cost. If the vehicle is unrepaired, state the address where and the hours when it may be seen. (Standard Motor Vehicle Tort Interrogatory No. 16.)

17. If you owned or were in a vehicle involved in the occurrence, state: when the vehicle was last repaired before the occurrence; the nature, dates, and costs of the repairs; the identity of the persons making the repairs; and the extent of any unrepaired damage to the vehicle immediately prior to the occurrence. (Standard Motor Vehicle Tort Interrogatory No. 17.)

18. If you contend that mechanical failure caused or contributed to the occurrence, state concisely the facts upon which you rely. (Standard Motor Vehicle Tort Interrogatory No. 18.)

19. If you were in a vehicle at the time of the occurrence, identify the owner and the driver of the vehicle. If you were not the owner, state whether you had the permission of the owner to be in the vehicle and the purpose for which permission was given. (Standard Motor Vehicle Tort Interrogatory No. 19.)

20. If you were the driver of a vehicle involved in the occurrence, state whether you have or have ever had any disability, illness, disease, or injury that could affect your ability to operate a motor vehicle, and describe its nature and extent. If treated or evaluated, identify all treating or examining health care providers and the approximate date of each examination or treatment. (Standard Motor Vehicle Tort Interrogatory No. 20.)

21. State whether you used any alcoholic beverages or drugs, whether controlled or otherwise, within 24 hours before the occurrence, the places where they were obtained, the places where they were used, and the nature and amount used. (Standard Motor Vehicle Tort Interrogatory No. 21.)

22. State the substance of all discussions concerning the occurrence that you or others in your presence had with any party to this case. State when and where each discussion took place and identify all persons who were present. (Standard Motor Vehicle Tort Interrogatory No. 22.)

23. State whether you have possession or knowledge of any recordings or transcripts of testimony in any proceeding arising out of the occurrence. If so, state the date and subject matter, and identify each person who recorded the testimony and the custodian of each recording or transcript. (Standard Motor Vehicle Tort Interrogatory No. 23.)

24. If you were in a vehicle involved in the occurrence, state whether the driver of the vehicle has a current driver's license. If so, state when and where the license was issued, the nature of any restrictions on the license, and whether the license was ever suspended or revoked. (Standard Motor Vehicle Tort Interrogatory No. 24.)

25. State whether, at any time during the fifteen year period preceding the date of your answers to these interrogatories, you have been convicted of any crime other than a minor traffic offense. If so, for each conviction identify the court in which you were convicted and state the amount of any fine and the date and length of any incarceration imposed. For purposes of this interrogatory, a conviction includes a plea of nolo contendere followed by a sentence, whether or not the sentence is suspended. (Standard Motor Vehicle Tort Interrogatory No. 25.)

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