Sample interrogatories from National General in one of Tien Law Firm’s personal injury litigation cases.

Interrogatory No. 1:  State the date and place of your birth, your present address, the length of time you have lived there, and each address you have used for the last five (5) years.

Interrogatory No. 2: State whether you are married or have ever been married, the name and address of your spouse, your date of marriage, and the names and birth dates of your children, if any.

Interrogatory No. 3: State the identity of your employer at the time of the incident described in the Complaint, the name of your immediate supervisor, the nature of your work, your business address, the days you worked each week, the number of hours you worked each week, and your average weekly earnings for the year immediately preceding the incident described in the Complaint. If you were self-employed or unemployed, please indicate this in your answer to this Interrogatory.

Interrogatory No. 4: State whether you claim any lost profits or earnings as a result of the incident described in the Complaint, all dates you missed from your employment as a result of said incident, and the amount of lost profits or earnings you claim as a result of said incident.

Interrogatory No. 5: State the names and addresses of all employers, including your present employer, that you have had since January 1, 2001, and describe your job, your job duties, the name of your supervisor, your hours and wages with these employers, and the specific dates of your employment. If self-employed, state the nature of your business, your gross and net earnings from your business for each year from January 1, 2001 through present.

Interrogatory No. 6: State your social security number, whether you have ever applied for or drawn social security benefits for disability, a detailed description of the disability giving rise to your claim for benefits, and the date your disability commenced and the length of time you drew disability benefits.

Interrogatory No. 7: Have you ever applied for or received any disability pension or income or workers’ compensation benefits from any person or entity? If so, state the dates you applied for and received such payments, the name and address of the person or entity making such payments, a detailed description of the injuries, disability, or condition giving rise to such payments, and a detailed description of the incident or circumstances from which this injury, disability, or condition arose, and a detailed description of the nature and extent of any present disability you are experiencing as a result of such injuries, disability, or condition.

Interrogatory No. 8: Describe in detail your hobbies or recreation activities. Include in your answer the date you began your participation in each such activity and the date you last participated in each such activity.

Interrogatory No. 9: Have you ever been convicted of a crime (including traffic offenses) in any state or federal court punishable as a felony or a Class Al, Class 1, or Class 2 misdemeanor? If so, state:
(a) The nature and date of the offense:
(b) The county and state in which you were tried or where the charge was otherwise handled or disposed of; and the fine or sentence imposed upon you.

Interrogatory No. 10: Did you consume any alcoholic beverage, or any sedative, tranquilizer, or other drug, medication, or pill during the 48 hours immediately preceding the incident described in the Complaint? If so, give a detailed description, including the name and amount, of each item consumed, the amount of time over which each item was consumed, and the names and addresses of all persons who have any knowledge concerning your consumption of these items.

Interrogatory No. 11: Have you ever suffered any mental or emotional illness or condition before or after the incident described in the Complaint? If so, give a detailed description of each such illness or condition, the dates you suffered each such illness or condition, the identity of the physician or other health care practitioner who examined or treated you in connection with such illness or condition, and the identity of all hospitals or other health care facilities in which you were examined or treated in connection with such illness or condition.

Interrogatory No. 12: Have you ever had any serious injuries, illness, sickness, disease, or surgical operations before the incident described in the Complaint? If so, give a detailed description of each such condition, the date you suffered from each such condition, the identity of any hospitals or other health care facilities rendering treatment to you, the identity of all physicians or other health care practitioners rendering treatment to you, and the approximate date of your recovery.

Interrogatory No. 13: Before the incident described in the Complaint, had you ever sustained any injury to or had any complaint about any part of your body that you contend was injured as a result of the incident described in the Complaint? If so, state the date, cause, nature and extent of such previous injury or complaint, and the identity of any hospitals or other health care facilities and physicians or other health care practitioners who rendered treatment to you for such injury or complaint.

Interrogatory No. 14: Have you ever been involved in any other legal action as a plaintiff or as a defendant? If so, give the identity of the court in which each such action was commenced, the date and place each such action was commenced, the identity of all other parties involved, the docket number of each such action, a detailed description of the nature of each such action, and the result of each such action.

Interrogatory No. 15: State the purpose of the trip you were on at the time of the incident described in the Complaint, your exact destination, and your time and point of departure.

Interrogatory No. 16: Describe in detail the manner in which you contend that the incident described in the Complaint occurred, specifying the speed, position, direction, and location of each vehicle involved during its approach to, at the time of, and immediately after this incident.

Interrogatory No. 17: As to each personal injury that you contend you suffered as a result of the incident described in the Complaint, state precisely the nature and location of each such injury, specifying the location, duration and intensity of any pain and any restraining of your normal activities that you contend resulted from such injuries, including the nature and dates of each such restraint.

Interrogatory No. 18: Do you contend that you suffered any mental or emotional illness or condition as a result of the incident described in the Complaint? If so, give a detailed description of each such illness or condition, the identity of any physician or other health care practitioner who examined, evaluated, or treated you for each such illness or condition, and the manner in which that illness or condition now affects you, including any way in which that illness or condition prevents you from performing any activities that you performed prior to the incident described in the Complaint.

Interrogatory No. 19: Do you contend that you have sustained a permanent disability as a result of any injuries you suffered in the incident described in the Complaint? If so, for each specified body part affected by such disability, state the specific injury that you contend caused each such disability, the percentage of disability for each specific body part which you contend was permanently disabled, a detailed description of the disability, such as limitations of motion, loss of sensory perception, or weakness, and the identity of any physician or other health care practitioner who has rendered an opinion as to the disability you have suffered.

Interrogatory No. 20: Identify every physician or other health care practitioner from whom you are still receiving medical or other health care services or treatment of any nature whatsoever as a result of the incident described in the Complaint, and if you contend and intend to offer evidence at trial that you need and will require future medical treatment or surgery; when and how frequently you contend such surgery or treatment will be needed; the costs and expense you contend will be incurred as a result of such future medical treatment or surgery; the basis for your contention or belief that such surgery or treatment will be needed in the future and the names and addresses of all physicians, health care providers or other persons that will testify at the trial of this case concerning such future medical treatment or surgery.

Interrogatory No. 21: State whether you now have any complaint with reference to any part of your body that you contend was injured as a result of the incident described in the Complaint, a detailed description of the nature and extent of that complaint, the approximate frequency with which you experience this complaint, and a detailed description of the manner in which the complaint prevents you from performing any activity that you engaged in prior to the accident described in the Complaint.

Interrogatory No. 22: State whether you claim any other item of damages, whether for personal injury, loss of time from work, lost wages, or any other item or economic loss for which you contend you are entitled to compensation from the Defendant as a result of the incident described in the Complaint and which item or economic loss have not previously been stated in your answers to the Interrogatories. If so, describe each such item of damage in detail, giving the nature, exact amounts you claim, all dates pertinent to each such item of damage, the nature and amount of any such economic loss, the date thereof, and the identity of any persons to whom any money so claimed was paid.

Interrogatory No. 23: Since the date of the incident described in the Complaint, have you been treated or examined by or conferred with any doctor or other health care practitioner of any description whose name you have not previously supplied in your answers to these Interrogatories, the identity of each such doctor or health care practitioner, and the condition for which you sought or received such treatment, care, or examination.

Interrogatory No. 24: At the time of the incident described in the Complaint, did you have a condition for which you wore eyeglasses or for which eyeglasses had been prescribed for you? If so, give a description of the condition for which eyeglasses had been prescribed for you, whether you were wearing eyeglasses at the time of the incident described in the Complaint, and the identity of the doctor or other health care practitioner who prescribed eyeglasses for you.

Interrogatory No. 25: Identify every person known to you or to your attorneys who purports to have seen or heard the Defendant make any statements concerning any matters at issue in this action, the location or locations where the Defendant made any such statements, the time and date upon which Defendant made any such statement or statements, and a verbatim statement, if possible, and a statement in substance if not, of each and every such statement.

Interrogatory No. 26: State verbatim, if possible, and in substance if not, each and every statement made by the Defendant in your presence at the scene of the incident described in the Complaint, and each and every statement made by you in the presence of the Defendant at this scene.

Interrogatory No. 27: Identify any and all documents, photographs, motion pictures, maps, drawings, diagrams, measurements, surveys, or other descriptions or depictions of any of the events or injuries described in the Complaint of which you or anyone acting on your behalf now or in the past are aware. In lieu of an answer below, please attach copies of these items to your answers.

Interrogatory No. 28: State the identity of each person whom you expect to call as an expert witness at the trial of this matter, the subject matter on which each expert is expected to testify, the substance of the facts or opinions to which each expert is expected to testify, and a summary of the grounds for each expert’s opinion.

Interrogatory No. 29: State whether you have ever made a claim for damages or benefits under any insurance policy, or against any person, firm or corporation, governmental agency or any other entity for personal injuries or illness and which you have not previously described in you answers to these Interrogatories, the injury, illness or condition for which each such claim was made, the identity of the person to whom or against whom each such claim was made, the date each such claim was made, and the nature and amount of any payment received for each such claim.

Interrogatory No. 30: State whether any medical expenses that you contend you incurred as a result of the incident described in the Complaint have been paid, directly or indirectly, by health insurance, Medicare, Medicaid, or any other program administered by the government of the United States or North Carolina, the name of the program or agency by which these payments were made, the health care provider to whom each payment was made, and the dates and amounts of each payment to each provider by each such program or agency.

Interrogatory No. 31: Identify all insurance companies, governmental or quasi-governmental agencies, or other third-party payment entities that may have an interest in any settlement proceeds or recovery obtained by you in this action.

Interrogatory No. 32: State the dates of all motor vehicle accidents in which you have been involved through the date of your answers to these Interrogatories, other than the automobile accident alleged in the Complaint in this action and state whether or not you were injured in those motor vehicle accidents, and the nature and extent of those injuries.

Interrogatory No. 33: Identify by name, address and telephone number each doctor, therapist, chiropractor or other health care practitioner who examined or treated you within the ten (10) year period immediately preceding the accident described in the Complaint. In lieu of an answer below, please attach copies of your medical records for the relevant time period.

Interrogatory No. 34: Describe all injuries (other than those received in this collision) you have ever received for which you sought the attention of a doctor, therapist, chiropractor or other health care practitioner. For each, give the dates of injury and the name, address and telephone number of the health care practitioner involved.

Interrogatory No. 35: Identify by name, address and telephone number every person known to you who may have knowledge of the facts of how this collision occurred. For each person identified, list the facts which each has related, directly or indirectly, to you or your attorney or to anyone who investigated this accident on your behalf.

Interrogatory No. 36: State the total amount of all medical expenses you allege were proximately caused by the collision described in the Complaint. (NOTE: Please do not avoid this question by directing the Defendant to refer to your medical bills.)

Interrogatory No. 37: List in an itemized fashion all medical expenses included in the total listed in Question No. 36 above. (Omit address and telephone numbers to the extent already listed above.)original) of any written, printed, typed, recorded, photographic, transcribed, photostatic, or graphic matter however produced or reproduced, including radiographs. This term shall include all medical reports, office notes, laboratory test results, admission summaries,
discharge summaries, charts, graphs, nurses’ notes, progress notes, physicians’ orders, operative reports, bills or other documents of any description generated by any medical or other health care personnel. This term shall include all documents in Plaintiff’s actual or constructive possession, custody, or control.

For help drafting and responding to interrogatories, requests for the production of documents, and other discovery matters, contact Tien Law Firm’s litigation lawyers at 1-888-988-6613.