After the Defendant has filed an Answer, Interrogatories, or thirty questions exchanged between the parties, are typically exchanged. Click to see a typical list of questions filed by the Auto Accident Lawyer Baltimore :


  1. State your full name, home address, date of birth, marital status and social security number.
  2. By whom were you employed and what were your duties and wages at the time of the occurrence?
  3. State the reason for termination of any employment during the last five (5) years.
  4. Name the eyewitnesses to all or part of the occurrence.
  5. Name all persons who were in or on your motor vehicle.
  6. Name all persons who were at or near the scene.
  7. Attach hereto a copy of any signed statement made by the Defendant or agent.
  8. If a report was made by you or by an employee of yours in the ordinary course of business with respect to the occurrence, state the name and address of the person who made the report, the date thereof and in whose custody it is.
  9. Give a detailed and full statement of the facts as to how you contend that the occurrence took place.
  10. If you contend that Plaintiff acted in such manner as to cause or contribute to the occurrence, give a detailed and full statement of the facts upon which you rely.
  11. If you contend that a person not a party to this action acted in such manner as to cause or contribute to the occurrence, give a detailed and full statement of the facts upon which you rely.
  12. Attach to your answers copies of all written reports made to you by any experts whom you propose to call as witnesses.
  13. State the itinerary of your vehicle, including the time and place of the beginning of the trip, the time and duration of each stop, the place of destination, and the expected time of arrival.
  14. Were you the owner of the vehicle operated by you at the time of the occurrence? If not, state the name and address of the owner, whether you had the permission of the owner to operate the vehicle, and the purpose for which you were operating the vehicle.
  15. Name all persons who investigated the cause and circumstances of the occurrence for you.
  16. Name all persons who arrived at the scene within one (l) hours after the occurrence.
  17. Name all persons who investigated Plaintiff’s injuries and damages for you.
  18. Name any person, not heretofore mentioned, having personal knowledge of facts material to this case.
  19. Name those persons who have given you signed statements concerning the occurrence.
  20. State whether you have within your possession or control photographs, plats or diagrams of the scene, or objects connected with said occurrence.
  21. State what part of your vehicle was damaged and, if it was repaired, the name and address of the person who performed such repairs, the dates of such work and the cost thereof. If such vehicle is unrepaired, state the address and the hours at which it may be seen.
  22. State the make, model, size and date of your motor vehicle and the date on which it was first placed in use by you.
  23. State nature and weight of the load which your motor vehicle was carrying and mileage covered by it.
  24. State when your vehicle was last repaired, prior to the date of accident, the nature, dates and costs of said repairs, and the names and addresses of the person making repairs.
  25. State whether you consumed any alcoholic beverages within eight (8) hours prior to said occurrence, the places where such alcoholic beverages were obtained, and the nature and amount thereof.
  26. State whether you have within your control, or have knowledge of any transcripts of testimony in any proceeding arising out of the occurrence. If so, state the date, the subject matter, the name and business address of the person recording said testimony and the name and address of the person who has present possession of each said transcript of testimony.
  27. When was your vehicle last inspected and by whom?
  28. Aside from minor traffic violations, has the Defendant ever been convicted of any offense under the criminal law of any State arising out of the operation of a motor vehicle or otherwise? If so, state the following:

(a) The date, the Court, the time and circumstances surrounding such conviction.

  1. Outline in detail the work schedule, physical and other activities for the Defendant(s) for the twenty four (24) hour period immediately preceding the occurrence.
  2. State with precision the type and amount of insurance coverage available to satisfy part or all of a judgment that might be entered in this action, or to indemnify or reimburse for payments made to satisfy the judgment, giving the policy number, name of insurance company, the agent, the named insured, and coverage limits.
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