Plaintiffs Interrogatories Directed To Defendant (Motor Vehicle Liability Cases)

FIRST JUDICIAL DISTRICT OF PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF PHILADELPHIA PLAINTIFF(S) CIVIL TRIAL DIVISION Compulsory Arbitration Program v. DEFENDANT(S) COURT TERM: NO. Plaintiff(s) Interrogatories Directed to Defendant(s) Motor Vehicle Liability Cases Plaintiff(s) hereby demands that the Defendant(s) answer the following Interrogatories pursuant to the Pennsylvania Rules of Civil Procedure 4001 et seq. These Interrogatories must be answered as provided in Pa.R.C.P. 4006 and the Answers must be served on all other parties within thirty (30) days after the Interrogatories are deemed served. These Interrogatories are deemed to be continuing as to require the filing of Supplemental Answers promptly in the event Defendant(s) or their representatives (including counsel) learn additional facts not set forth in its original Answers or discover that information provided in the Answers is erroneous. Such Supplemental Answers may be filed from time to time, but not later than thirty (30) days after such further information is received, pursuant to Pa.R.C.P. 4007.4. These Interrogatories are addressed to Defendant(s) as a party to this action; Defendant's(s') answers shall be based upon information known to Defendant(s) or in the possession, custody or control of Defendant(s), their attorney or other representative acting on Defendant's(s') behalf whether in preparation for litigation or otherwise. These Interrogatories must be answered completely and specifically by Defendant(s) in writing and must be verified. The fact that investigation is continuing or that discovery is not complete shall not be used as an excuse for failure to answer each interrogatory as completely as possible. The omission of any name, fact, or other item of information from the Answers shall be deemed a representation that such name, fact, or other item was not known to Defendant(s), its counsel, or other representatives at the time of service of the Answers. If another motor vehicle was not involved in the alleged accident, then interpret any questions to include a non-motor vehicle (e.g. pedestrian, bicycle, etc.). BACKGROUND INFORMATION 1. Please identify if you are an individual, corporation or partnership: (a) If an individual: (1) full name (maiden name, if applicable) American LegalNet, Inc. www.FormsWorkFlow.com (2) alias(es) (3) date of birth (4) residence or business addresses at time of the alleged accident and currently. (b) If a corporation: (1) registered corporation name (2) principal place of business (3) registered address for service of process at the time of the alleged accident and currently. (c) If a partnership: (1) registered partnership name (2) principal place of business (3) registered address for service of process at the time of the alleged accident and currently (4) the identities and residence addresses of each partner at the time of the alleged accident and currently. American LegalNet, Inc. www.FormsWorkFlow.com 2. If you (and/or your operator) were employed, state: (a) Employer on the date of the accident; (b) Your title or position and accompanying duties and responsibilities on the date of the accident; (c) The length of your employment on the date of the accident. 3. If at the time of the alleged accident, you (or your operator) possessed a valid license to operate a motor vehicle, state: (a) The Commonwealth or State issuing it; (b) The issuance date and expiration date; (c) The operator's number of such license; (d) The nature of any restriction(s) on said license; 4. Identify: American LegalNet, Inc. www.FormsWorkFlow.com (a) Your applicable motor vehicle insurance carrier at the time of the alleged accident; (b) Your applicable liability insurance coverage limits at the time of the alleged accident; (c) Your applicable umbrella and/or excess liability insurance coverage limits at the time of the alleged accident; (d) If self-insured, for all or any monetary part of a liability claim, so state (including the limits). 5. If you (or your operator) had a driver's license suspended or revoked in the last ten (10) years, state: (a) When, where and by whom it was suspended or revoked; (b) The reason(s) for such suspension or revocation; (c) The period of such suspension or revocation; (d) Whether such suspension or revocation was lifted and if so, when. 6. Have you been convicted of or pleaded guilty or nolo contendere to any crime(s) in the past ten (10) years to any crime(s) involving dishonesty or false statements as provided in American LegalNet, Inc. www.FormsWorkFlow.com Pa.R.E. 609, or has last date of confinement for said crime(s) been within the past ten (10) years? ACCIDENT INFORMATION 7. State the purpose of the motor vehicle trip you (or your operator) were on at the time of the alleged accident. 8. State whether or not you (or your operator) were familiar with the scene of the alleged accident and how often you traveled through same. 9. Was the Defendant's motor vehicle damaged as a result of the alleged accident? If so, describe the damage in detail. 10. Identify the person and/or company who repaired and/or evaluated your motor vehicle to prepare a repair estimate. 11. If the motor vehicle you were the owner and/or driver or occupant of has been sold since the time of the accident, state the date of the sale, identify by name and address the person who purchased the motor vehicle and the sale price of the motor vehicle. 12. If you (or your operator) consumed any alcoholic beverage(s), medications American LegalNet, Inc. www.FormsWorkFlow.com (prescription and/or over-the-counter) or any illicit drugs, during the forty-eight (48) hours immediately preceding the alleged accident, state: (a) The nature, amount and type of item(s) consumed; (b) The period of time over which the item(s) was/were consumed; (c) The names and addresses of any and all persons who have any knowledge as to the consumption of the aforementioned items (e.g. witnesses, physicians, etc.). 13. At the time of the alleged accident, did you (or your operator) suffer from any deformity, disease, ailment, disability or abnormality that may have affected your ability to operate a motor vehicle? physician for that condition, if any. If so, identify the condition and the treating 14. Identify the date, time and location of the alleged accident. 15. Describe the lighting conditions, weather conditions and the condition of the road(s) surface(s) existing at the time and place of the alleged