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Plaintiffs Interrogatories Directed To Defendant (Motor Vehicle Liability Cases) - Pennsylvania

Plaintiffs Interrogatories Directed To Defendant (Motor Vehicle Liability Cases) Form. This is a Pennsylvania form and can be used in Civil Trial Philadelphia Local County .
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FIRST JUDICIAL DISTRICT OF PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF PHILADELPHIA COUNTY PLAINTIFF'S NAME vs. DEFENDANT'S NAME : : : : : : : : Civil Trial Division Compulsory Arbitration Program Term, 20 No. Plaintiff's Interrogatories Directed To Defendant(S) Motor Vehicle Liability Cases Plaintiff(s) hereby make demand 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 30 days after such further information is received, pursuant to Pa. R.C.P. 4007.4. These Interrogatories are addressed to you as a party to this action; your answers shall be based upon information known to you or in the possession, custody or control of you, your attorney or other representative acting on your behalf whether in preparation for litigation or otherwise. These Interrogatories must be answered completely and specifically by you 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), their 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 (i.e. pedestrian, bicycle, etc.). 1. State: (a) If an individual: Full name (maiden name, if applicable), alias(es), date of birth, marital status (name of spouse) at the time the cause of action arose and currently, residence and business addresses at time of cause of action and currently and Social Security Number. (b) If a corporation: registered corporation name, principal place of business and registered address for service of process at the time the cause of action arose and currently. (c) If a partnership: registered partnership name, principal place of business and registered address for service of process at the time the cause of action arose and currently as well as the identities and residence addresses of each partner at the time the cause of action American LegalNet, Inc. arose and currently. 2. If you (and/or your operator) were/are employed, state: (a) By whom, at the time the cause of action arose and currently; (b) Your title or position and accompanying duties and responsibilities at the time the cause of action arose and currently; (c) The length of your employment as of the time the cause of action arose and currently. 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: (a) Your applicable motor vehicle insurance carrier at the time the cause of action arose; (b) Your applicable liability insurance benefits coverage limits; (c) Your applicable umbrella and/or excess liability insurance benefits coverage limits at the time the cause of action arose. 5. If you (or your operator) ever had a driver's license suspended or revoked, state: (a) When, where and by whom it was suspended or revoked; American LegalNet, Inc. (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. If you (or your operator) have had a claim made against you for the negligent operation of a motor vehicle within the last five (5) years, state: (a) Your applicable motor vehicle liability insurance benefits carrier at the time that cause of action arose; (b) The Commonwealth or State, County, Court, Term and Number of any lawsuits arising from that cause of action. 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. If the Defendant's motor vehicle involved in the alleged accident was damaged in any manner, describe in detail. 10. If you (or your operator) consumed any alcoholic beverage(s), medications (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 (i.e. witnesses, physicians, etc.) American LegalNet, Inc. 11. If at the time of the alleged accident, you (or your operator) suffered from any deformity, disease, ailment, disability or abnormality, or were under a physician's care for any condition, then describe. 12. Identify your (and/or your operator's) family (or "primary care") physician and their professional address at the time the cause of action arose and currently. 13. Describe the lighting conditions, weather conditions and the condition of the road(s) surface(s) existing at the time and place of the alleged accident. 14. If there were any traffic control devices in the area of the alleged accident at that time, state: (a) The type of control(s)(i.e. stop sign, traffic light, policeman, etc.); (b) Your distance from the site of the collision when you first observed the control; (c) Whether or not the traffic control was functioning properly; (d) To which street or byway the signal was controlling or designed to control. 15. Describe the streets or other byways involved in the a
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