Defendants Interrogatories Addressed To Plaintiff (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) Defendant's Interrogatories Addressed to Plaintiff(s) Motor Vehicle Liability Cases Defendant(s) hereby make demand that the Plaintiff(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 Plaintiff(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 Plaintiff(s) as a party to this action; Plaintiff's(s') answers shall be based upon information known to Plaintiff(s) or in the possession, custody or control of Plaintiff(s), their attorney or other representative acting on Plaintiff's(s') behalf whether in preparation for litigation or otherwise. These Interrogatories must be answered completely and specifically by Plaintiff(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 Plaintiff(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 (e.g. pedestrian, bicycle, etc.). BACKGROUND 1. Please identify if you are an individual, corporation or partnership: (a) If an individual: (1) full name (maiden name, if applicable) (2) alias(es) (3) date of birth (4) Social Security Number American LegalNet, Inc. www.FormsWorkFlow.com COURT TERM: NO. (5) residence and 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 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 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. 2. If you are currently employed, were employed at the time of the alleged accident and/or employed for five (5) years before the accident date, state as to each time period: (a) By whom; (b) Your stated title or position and accompanying duties and responsibilities; (c) The length of your employment; (d) Number of hours worked per week and/or number of days worked per week; (e) Hourly wage and/or salary as well as supplemental wages (e.g. bonuses, overtime, etc.). American LegalNet, Inc. www.FormsWorkFlow.com 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; (e) Whether you ever possessed a valid driver's license. 4. With regard to the motor vehicle in which you were an occupant at the time of the accident, identify: (a) The applicable motor vehicle insurance carrier at the time of the alleged accident; (b) The applicable liability insurance coverage limits at the time of the alleged accident; (c) The applicable umbrella and/or excess liability insurance coverage limits at the time of the alleged accident. 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. American LegalNet, Inc. www.FormsWorkFlow.com 6. Have you made a claim or filed a lawsuit for personal injury within the last ten (10) years? If so, state: (a) Against whom the claim or lawsuit was made including the name and address of any insurance carrier and/or parties; The Commonwealth or State, County, Court, Term and Number of any lawsuits arising from that cause of action; (b) (c) The outcome of the claim/lawsuit. 7. Were you the owner or resident relative of an owner of a motor vehicle(s) at the time of the alleged accident? If so, state: (a) Where the motor vehicle(s) was registered; (b) Was the motor vehicle insured; (c) The name of the insurance company and your insurance coverage; (d) Your tort status under your insurance policy (full tort or limited tort). 8. 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 Pa.R.E. 609, or has last date of confinement for said crime(s) been within the past ten (10) years? ACCIDENT INFORMATION 9. State the purpose of the motor vehicle trip you (or your operator) were on at the time of the alleged accident. 10. State whether or not you (or your operator) were familiar with the scene of the alleged accident and how often you traveled through same. 11. Was the Plaintiff's motor vehicle damaged as a result of the alleged accident? If so, describe the damage in detail. American LegalNet, Inc. www.FormsWorkFlow.com 12. Identify the person and/or company who repaired and/or evaluated your motor vehicle to prepare a repair estimate. 13. 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. 14. If you (or your operator) consumed any alcoholic beverage(s), medications (prescr