Summary. The top of the first page of your interrogatories must include the same caption that appears at the top of the first page of every document that has been filed with the court in your case. Plaintiff’s Interrogatories To Defendant. Use this to your advantage. While the Interrogatories you receive may not be exactly like these, they will be substantially similar. (410)779-4600. IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND. These questions are referred to as “Interrogatories”. NAME] (“Defendant”), to serve further, verified responses, without objections to Special Interrogatories, Set No. Please read through these Interrogatories and prepare your responses, this will save you time Example interrogatory questions to defendants in personal injury cases. Special Interrogatories. Sample Premises Liability Interrogatories. 8681 SPECIAL INTERROGATORIES SPECIAL INTERROGATORY NO. This can result from requiring disclosure of information that’s constitutionally protected. California Code of Civil Procedure - Interrogatories Table of Contents Propounding Interrogatories [CCP 2030. , Suite 702 . INTERROGATORIES TO DEFENDANT (Slip/Trip/Fall) 1. . Leaving that on the side, special interrogatories cannot be used to compel a party to produce a document. If you cannot answer an interrogat}{\rtlch\fcs1 \af0\afs24 \ltrch\fcs0 \f0\fs24\insrsid9767527\charrsid11283428\hres1\chhres0 o}{\rtlch\fcs1 \af0\afs24 \ltrch\fcs0 \f0\fs24\insrsid9767527\charrsid11283428 ry completely, answer it to the extent possible. Common ones in most civil cases are: Form Interrogatories – General (form DISC-001) (for use in unlimited civil cases) Form Interrogatories – Limited Civil Cases (Economic Litigation) (form DISC-004) (for use in limited civil cases) Remember that special interrogatories are questions requesting written answers, and cannot be used to compel the responding party to produce documents. § 5:48. Assert objections to the interrogatories without providing a further answer. Federal Court Proceedings. (1) In General. Aug 1, 2013 •. Below are sample interrogatories that we served on GEICO in a uninsured motorist case. The court may do so by: (A) submitting written questions susceptible of a categorical or other brief answer; Identification 1. 5. 260; CCP § 1013; CRC 2060(b)(2). 090] 2030. Remember that special interrogatories are questions requesting written answers, and cannot be used to compel the responding party to produce documents. With respect to the person answering these interrogatories, state his or her name, address, business address, job title, occupation, name of immediate supervisor, length of employment with the defendant employer, and the length of time in current position. This discovery request as phrased is argumen­ tative. 040 - Declaration For Additional Special Interrogatories, Option of Seeking Protective Order Example interrogatory questions to defendants in personal injury cases. 2 likes • 12,849 views. 47(l), 347(l). Below are sample interrogatory questions propounded in a typical car accident lawsuit. 1. These sample special interrogatories for California is for a California civil case and is intended to be used by a defendant but can be modified for use by a plaintiff. Typically, responses are due within 30 days from the date of personal service, or within 35 days if you were served by mail ( CCP §2030. See C. Just below the top caption identifying the case, the form identifies the Answering (or First, you must mail “Form” and “Special Interrogatories” to the other side. C. Telephone: 310. 47(r) & (s), 347(r) & (s). TO: JAMES KROL, DEFENDANT. 24-C-02-00380. This sample can serve as a starting point when drafting interrogatories. Apr 21, 2009 · Responses to interrogatories are due within thirty (30) days if the interrogatories were personally served, thirty-five (35) days if the interrogatories were served by mail, and thirty (30) days plus two (2) court days if the interrogatories were served by express mail or facsimile or electronically. 1: Please state YOUR full name, home address (and all addresses for the last five (5) years, social security number, date of birth, marital status and your employer’s name and address. LegalDocsPro. IN THE UNITED STATES DISTRICT COURT. g. Answer: 2. This might be risky — the opposing attorney may file a motion to compel if your objections are not legally valid. [#] served on Defendant on [Date]. Sample interrogatories in all types of personal injury, medical malpractice, and wrongful death cases. 060, subd. ” Any discovery request that requires the adoption of an assumption is argu­ mentative. ”. Facsimile: 310. Miller & Zois, LLC. In California, each party is allowed to send 35 special interrogatories to another party, and anything above 35 requires the sending party to show some sort of necessity. Learn more about responding and objecting to interrogatories. Sample Product Liability Interrogatories. effective by taking away from the jury some of its power to take the law into its own hand. 3: Provide a summary of the expected testimony of each witness identified in response to Interrogatory No. Use a Special Interrogatory (sometimes called a Specially Prepared Interrogatory) if you want to write the questions yourself. For federal litigation, and in state courts which similarly limit discovery, the following sample interrogatories must be reduced to 25 interrogatories. Share sensitive information only on official, secure websites. 287555) dselarz@selarzlaw. In a slip and fall case, the main issue is usually whether the property owner -- or whoever was charged with maintaining the property -- failed to take reasonable steps to prevent the plaintiff’s accident. You can use the following key defined terms and phrases: • “DOCUMENT” and “DOCUMENTS” shall mean and include (1) any “Writing,” “Original,” and “Duplicate” as should do so, for example, if one or more members of the jury failed to sign the verdict form returned. Sample interrogatories for the plaintiff in a slip and fall lawsuit. C. Other Premises Liability Links. 010 - General Information on Interrogatories. Each Interrogatory is to be answered fully on the basis of information which is in your possession. , § 2030. The difference between a special verdict and special findings in response special interrogatory no. Dec 3, 2018 · In federal court, the number of interrogatories is limited to 25 per party. Sample Interrogatories. These are sample written questions that you might receive in your divorce. , Suite 702 Los Angeles, California 90049 Tel: 310. VII. Laura G. Sometimes, it is hard to come up with the exact words of why you want to object or to match the feeling that the request is objectionable with the appropriate law. In a limited civil case (cases less than $25,000, or $35,000 if filed after Jan. 1 South St, #2450. Example interrogatory questions to defendants in personal injury cases. Below are sample interrogatories in a dog bite lawsuit. It requires the adoption of an assumption, which is improper. The classic example is, “When did The title of the form will typically be either special interrogatories or specially prepared interrogatories. FROM: ASHLEY BURTON Jan 31, 2023 · Let's assume, for example, that in a car wreck case, the plaintiff claims the defendant was drunk at the time of the collision. More sample discovery; List of Sample Objections . For example, they will ask for names, addresses, phone numbers, birth dates, employment, etc. Example Dog Bite Interrogatories. Requests for Admission. June 28, 2023. (410)760-8922 (Fax) Attorneys for the Plaintiff. OBJECTIONS: Complainant reiterates and restates each Objection from above, and adds that this Interrogatory requests information subject to privilege, including attorney work product. Without any thought whatsoever, there discovery responses will imply that your client is a malingering Remember that special interrogatories are questions requesting written answers, and cannot be used to compel the responding party to produce documents. This is objectionable as to form. Zois. It's a set of questions on a standard form. The defendant denies being drunk. (. CCP §2023. 4 days ago · The meaning of SPECIAL INTERROGATORY is an interrogatory addressed to a jury seeking a determination of a specific issue or issues of ultimate fact for the purpose of testing the deliberations and conclusions of the jury for consistency with the general verdict or when the court requires the jury to return a special verdict. 651. Example Interrogatories for Uninsured Motorist Claim. Request For Admissions. Proc. [6] [7] This caption should look exactly the same as the caption on every other document. Chapter 5. Remember, insurance companies reflexively deny everything in discovery. End of Document. Miller, Jr. You use this if you want to ask questions that are specific to your case and are not included on the Form Interrogatory form. P. You are required to respond to these interrogatories no later than thirty (30) calendar days after receipt of these A Form Interrogatory is the easiest tool to use for discovery. Forms, Pleadings and Practice Aids. , Suite 702 Los Angeles, California 90049 [DEFENDANT(S)] Tel: SELARZ LAW CORP. 1, 2024) you may ask each party only 35 questions total, whether they are form Each Interrogatory is to be answered fully on the basis of information which is in your possession. 11777 San Vicente Blvd. This annotated standard form is a defendant’s special interrogatories to a plaintiff in a disability discrimination employment litigation matter. Free Consultation (800) 553-8082 Miller & Zois helps injured victims and their families in personal injury, medical malpractice and wrongful death cases. The number and type of alcoholic drinks the defendant had in the hours leading up to the wreck clearly would be relevant, and a proper discovery subject. Below is a sample set of plaintiff’s product liability interrogatories to the defendant. 030 - Limitation on Number of Interrogatories That May Be Served. Carefully review the Complaint, alleged facts, causes of action, and affirmative defenses when preparing interrogatories. State laws regarding interrogatory limits vary. PLAINTIFF’S SUPPLEMENTAL INTERROGATORIES, SET ONE S ELARZ L AW ORP. This limitation may be avoided only by leave of court or written stipulation of the parties. Jul 10, 2023 · First, it’s questionable if placing specially defined terms at the beginning of your special interrogatories is permitted as CCP §2030. Oct 28, 2016 · Sample Interrogatories for Social Media Discovery. These sample questions are provided as examples in a fictitious case: Nov 5, 2018 · Slip and Fall Interrogatories Sent From Plaintiff to Defendant. Written interrogatories are a useful discovery tool for plaintiffs in all types of tort cases. Other informal discovery types include handcrafted “Requests for Admissions,” asking Remember that special interrogatories are questions requesting written answers, and cannot be used to compel the responding party to produce documents. (a) Special Verdict. Please state your full name, your present home address, your employer’s name and business address, and the title you hold with the named defendant, or the capacity in which you are associated with said defendant. 4: Identify all persons who arrived at the scene within two (2) hours after the Sample Car Accident Interrogatories. DANIEL E. 020 - Timing For Serving Interrogatories. View on Westlaw or start a FREE TRIAL today, § 5:48. 010 (c). The following examples of special interrogatories were drafted in compliance with two primary considerations: first, the wording and format of the special interrogatories should not favor any one party; 3 . CCP § 2030. A party may object to interrogatories when being required to answer would result in “unwarranted annoyance, embarrassment, or oppression, or undue burden and expense. Ronald V. Jury Instructions, Interrogatories and Special Verdicts. 060 (d) requires each special interrogatory be “full and complete in and of itself. Common objections include: The request is impermissibly compound. Los Angeles, California 90049 . second, the composition of the interrogatories * These sample interrogatories were prepared by John F. Baltimore, MD 21202. gov website. If you were served by mail, you typically have 35 days from the date of mailing to respond. SET NUMBER: ONE (1) Plaintiffs propound the following interrogatories pursuant to Rule 33 of the Federal Rules of Civil Procedure to Defendant. The jury may retire for their deliberations or arrive at a verdict in court. At the bottom are sample interrogatories the plaintiff can expect in a product defect, manufacturing defect, or defective warning case from the defendant. In each of your answers to these Interrogatories, you are requested to provide not only such information as is in your possession, but also information as is reasonably available. State the names and addresses of all persons known to you or to your Dec 15, 2023 · Step 4: Draft the Special Interrogatories. Sometimes, rather than answering the interrogatory, you may wish to object to the request on legal grounds. Get sample interrogatories that show the best questions to ask depending upon the type of civil case. Before you start. ANSWER TO INTERROGATORY NO. com . 3: Immediately after the accident, Plaintiff, her son and the Defendant were present at the scene of the accident, thereafter, the Defendant left the scene. 8685 • Fax: 310. The following standard document is for illustrative purposes only and should not be used without careful research and adaptation for the facts and circumstances of the Aug 1, 2013 · Sample special interrogatories for California. These particular questions seek to identify something. Special interrogatories should be drafted on pleading paper with numbered lines and the appropriate case caption and the requisite case and party information. Just below the top caption identifying the case, the form identifies the Answering (or A. Create your caption. Our also attorneys provide more information on dog bite lawsuits and discovery below that can help you with deposition questions, interrogatories, and requests for production of documents. Use the interrogatories of others and samples in the resources listed below as a model to assist with drafting your interrogatories. 8685 . Oct 18, 2023 · A locked padlock) or https:// means you’ve safely connected to the . To win the lawsuit, the plaintiff usually has to prove the defendant’s Complainant, through her counsel, Snider and Fischer LLC, requests that the Agency respond to the following interrogatories. Objections to interrogatories • Argumentative: “Objection. Jan 22, 2022 · 3. SELARZ (State Bar No. The court may require a jury to return only a special verdict in the form of a special written finding on each issue of fact. Notice is furthergiven that Plaintiff will request that the Court award monetary sanctions against Defendant and Defense Counsel, and in favor of Plaintiff in the sum of Example interrogatory questions to defendants in personal injury cases. You have 30 days after the form or special interrogatories were served to you (35 days if served by mail from within California) to serve your responses to the interrogatories. 260 and CCP §1013 ). R. \par \tab In answering these interrogatories, furnish all information that is available to you. Ask. CASE NO. 010 - 2030. 2. In accordance with Rule 33, you are required to serve a written response under oath to each of these interrogatories no later than thirty (33) days from the date of mailing. [#], Interrogatories Nos. Code Civ. Please identify each internet-based social networking site that you have used during the past five years (e. Identification 1. Cyrus and Gene W. ASHLEY BURTON- Plaintiff v JAMES KROL- Defendant. The title of the form will typically be either special interrogatories or specially prepared interrogatories. Special interrogatories for a § 1983 case—Sample form. 20: Please state whether YOU had any other insurance policies in effect at the time of the SUBJECT INCIDENT covering bodily injuries caused to other person. 2030. Federal Rule Civil Procedure 33(a) limits the number of interrogatories to 25 including subparts. But, in so far as civil cases are con-cerned, this power is not2, and it is submitted, should not be, protected by constitutional safeguards. The propounding party must number each set of interrogatories consecutively. To simplify the document demands, interrogatories, and requests for admissions, it is helpful to include defined terms or phrases. May 23, 2018 · Annoyance, embarrassment, oppression. Form interrogatories are an easy way for parties to ask common questions by simply checking the boxes for the questions they wish to ask. You have 30 days to respond to the interrogatories. Maryland Personal Injury Lawyers. Jul 12, 2024 · A sample Response to Special Interrogatories with a Verification can be found below. These was another individual at the scene as identified above. Additionally, make sure to reduce subparts to facts, documents, and witnesses related to the primary contention or allegation. special interrogatory no. fm, Blogspot, Each Interrogatory is to be answered fully on the basis of information which is in your possession. SPECIAL INTERROGATORIES TO JURIES 301. Good luck with your case! Sample dog bite complaint. Interrogatory No. Get interrogatories and other discovery to serve on defendant in slip and trip cases. A Special Interrogatory doesn't use a specific court form. Sample Answers to Interrogatories. These same rules prescribe the responsibilities of the bailiff if the jury does retire for their Each Interrogatory is to be answered fully on the basis of information which is in your possession. You are required to answer these interrogatories separately and fully in writing, under oath. eq bg hl zf qw bt zb pc iu za