Instructions to Clients – Answering Interrogatories

1. WHAT ARE INTERROGATORIES? The other side has served us with Interrogatories, which are simply questions which must be answered. YOU MUST GET YOUR ANSWERS TO US WITHIN THE NEXT FEW DAYS, WRITTEN ON A SEPARATE SHEET OF PAPER. You are required to answer these under the rules of Court.
2. PROCEDURE. After we have received your answers, we will add additional information we know and then have you sign the final copy. We cannot leave out any witnesses or any information because it will eventually hurt your case. The penalty for leaving out any witnesses is that they may not testify at trial and, therefore, could not help you. If, after answering the Interrogatories, new witnesses are discovered, be sure to let us know so we can amend the Interrogatories.
3. DOCTOR VISITS AND BILLS. We will give the defendant a medical waiver for them to get this information. We are required to do this by law.
4. OTHER ACCIDENTS OR INJURIES. If you are asked about prior accidents (accidents or injuries before this one), be sure that you indicate the date the doctor treated you, the nature of the accident and the nature of your injuries. It is very important that you indicate all previous accidents and all previous injuries. This means such injuries as childhood falls, football injuries, war injuries and the like. FAILING TO TELL THE TRUTH COULD LEAD TO LOSING YOUR CASE. If you have had a previous back or neck injury, for example, there is nothing wrong with this fact, as you may be more susceptible or more easily injured in a second accident. However, the failure to tell this could easily give the impression that you were trying to hide something or lie. YOU MUST ALWAYS TELL THE COMPLETE TRUTH.
5. SPECIAL DAMAGES. The phrase “special damages” simply means all your expenses. If you are asked to list all special damages or all losses, then list all of your expenses from the accident, including such things as the following: (1) Doctor bills; (2) Hospital bills; (3) Car repair bill; (4) Physical therapy bills; (5) Clothing loss; (6) Costs of trips to the doctor and hospital; (7) Wage or earning loss; (8) Nursing expenses; (9) Car rental; (10) Housekeeping expenses; (11) Brace, collar, wheelchair, crutches, etc., expense; (12) Babysitting expenses; and (13) Drugs and medicine expenses.
6. ANSWER ALL QUESTIONS IF POSSIBLE. There are some questions on the Interrogatories, for example, concerning whether or not photographs have been taken of the vehicles which only we would know about. We will answer these questions when we receive your answers. If you, however, know about photographs, or know anything about any of the questions, you should answer on a separate sheet of paper.
7. QUESTIONS AND HELP IN ANSWERING. It will save us a tremendous amount of time if you are careful and detailed in preparing your own answers. This will help you later when you have to give your deposition or statement under oath. You might want to keep a copy of your answers for your further reference. If you need help give us a call.