THE COURTS
Title 249--PHILADELPHIA RULES
PHILADELPHIA COUNTY
Standard Interrogatories in Compulsory Arbitration Cases; Motor Vehicle Liability and Premises Liability Cases; Trial Division Administrative Doc. No. 2005-02
[35 Pa.B. 2605]
Order And Now, this 8th day of April, 2005, upon consideration of the stated purposes of the Compulsory Arbitration Program, which is designed to enable the Court and the litigants to equitably, fairly, and expeditiously dispose of certain types of cases, see 42 Pa.C.S. § 7361, Pa.R.C.P. 1301 et seq., and Phila.Civ.R. *1301 et seq., and upon review and consideration of Pa.R. C.P. 4005, which authorizes the Court to adopt, and limit, the number of standard interrogatories as justice may require, it is hereby Ordered, Adjudged, and Decreed that as to Motor Vehicle Liability and Premises Liability cases assigned to the Compulsory Arbitration Program:
1) The following ''Standard'' Interrogatories are adopted by the Court:
a) Plaintiff's Interrogatories Addressed to Defendant--Motor Vehicle Liability, Exhibit ''A''
b) Defendant's Interrogatories Addressed to Plaintiff--Motor Vehicle Liability, Exhibit ''B''
c) Plaintiff's Interrogatories Addressed to Defendant--Premises Liability, Exhibit ''C''
d) Defendant's Interrogatories Addressed to Plaintiff--Premises Liability, Exhibit ''D.''
2) The following Requests for Production of Documents are adopted by the Court:
a) Plaintiff's Request for Production of Documents, Exhibit ''E'' and
b) Defendant's Request for Production of Documents, Exhibit ''F.''
3) Objections. The Court will not entertain objections to the standard interrogatories or document requests. Parties who serve objections may be subject to appropriate sanctions, including imposition of counsel fees.
4) Service of Standard Interrogatories and Requests for Production of Documents.
At any time after the filing of an Answer to the Complaint, a party may request any other party to answer standard interrogatories and/or respond to standard document request by serving on all other parties a Notice to Answer or Respond To Standard Written Discovery, substantially in the form attached hereto as Exhibit ''G.'' Answers and responses shall be provided to all parties within thirty days of the service of the Notice, but shall not be filed with the Court or Prothonotary unless relevant to a motion or other pretrial proceeding, ordered by the court or required by statute. Once the Notice is served on any party, all other parties, including the parties serving the Notice, shall answer the standard interrogatories applicable to them within thirty days of the service of the original Notice. Only the standard interrogatories and document requests approved herein shall be served and answered by the parties, except as provided in paragraph (6) hereunder.
5) A copy of the standard interrogatories or document requests need not be attached to the Notice served on attorneys, but must be provided to unrepresented parties. Copies of the above documents may be obtained on the court's website, at http://courts.phila.gov.
6) Additional Written Discovery
(a) General Rule. No additional interrogatories or document requests will be permitted as to Motor Vehicle and Premises Liability cases filed in the Compulsory Arbitration Program unless the answering or responding party agrees, or as further provided hereunder.
(b) Limited Supplementation. Any party may serve up to five (5) additional interrogatories or document requests that are specifically tailored to the case and are not duplicative of the standard interrogatories or document requests. Each subpart shall be considered a separate interrogatory or request for purposes of this limitation.
(c) Arbitrational Appeals. Any party may serve up to ten (10) additional interrogatories, within thirty days of the filing of an appeal from an Arbitration Award. Each subpart shall be considered a separate interrogatory for purposes of this limitation.
(d) Leave of Court. Upon receipt of answers to standard interrogatories or responses to standard document requests, any party may file an appropriate discovery motion under Phila. Civ.R. *208.3, seeking leave of court to serve additional interrogatories or document requests. The moving party must allege and show good cause why the additional standard interrogatories or document requests are reasonably necessary to prepare its case for trial.
7) Dead Man's Rule. In the event that any party wishes to invoke the Dead Man's Rule, that party shall notify the opposing party, in writing, of its intention to invoke said Rule, within twenty (20) days of the time the Notice to Answer or Respond to Standard Written Discovery was served. In such a case, the party who is invoking the Dead Man's Rule shall have no obligation to answer the standard interrogatories or produce the documents requested, until otherwise ordered by the Court.
8) Effective Date. This Administrative Order will become effective on June 6, 2005.
This Administrative Order is promulgated in accordance with the April 11, 1986, Order of the Supreme Court of Pennsylvania, Eastern District, No. 55 Judicial Administration, Docket No. 1, Pa.R.C.P. 4005 and Pa.R.Civ.P. 239. As required by Pa.R.Civ.P. 239, the original Administrative Order shall be filed with the Prothonotary in a docket maintained for Administrative Orders issued by the Administrative Judge of the Trial Division, and copies shall be submitted to the Administrative Office of Pennsylvania Courts, the Legislative Reference Bureau and the Supreme Court Civil Procedural Rules Committee. Copies of the Regulation shall also be submitted to American Lawyer Media, The Legal Intelligencer, Jenkins Memorial Law Library and the Law Library for the First Judicial District of Pennsylvania, and posted on the website of the First Judicial District at: http://courts.phila.gov.
By the Court
JAMES J. FITZGERALD, III,
Administrative Judge
EXHIBIT ''A''
FIRST JUDICIAL DISTRICT OF PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF PHILADELPHIA COUNTY
PLAINTIFF'S NAME : Civil Trial Division : : Compulsory Arbitration : Program vs. : : ______ Term, 20 : DEFENDANT'S NAME : 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 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;
(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.)
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 alleged accident, as follows:
(a) In terms of traffic lanes (i.e. parking, travel, turn-only lanes), the width of the streets or other byways;
(b) Type of road surface (i.e. concrete, black top, dirt, gravel, etc.);
(c) Roadway surface condition(s) (i.e. dry, wet, muddy, etc.);
(d) Any defects in the roadway which you believe contributed to the happening of the alleged accident.
16. State in detail the manner in which the alleged accident occurred, specifying the speed, position, direction and location of each motor vehicle involved, just before, at the time of, and immediately after the alleged accident.
17. State:
(a) In which lane the respective motor vehicles were traveling before the alleged accident occurred and in which lane the alleged accident occurred;
(b) When you first observed the other motor vehicle (or pedestrian, bicycle, etc.) involved in the alleged accident, stating the distance at that moment from the ultimate point of contact and the respective speeds of the motor vehicles at that time;
(c) The speed of your vehicle;
(1) At 100 feet from the point of contact;
(2) At 50 feet from the point of contact;
(3) At the point of contact.
(d) Whether your (or your operator's) view was clear or what obstruction, if any, existed at the time of the alleged accident;
(e) What you (or your operator) did in an attempt to avoid the alleged accident;
(f) The exact point of contact of the motor vehicles, in terms of distance from the various curb lines or other significant landmarks and their final resting positions;
(g) Whether the responding and/or investigating police officers cited any of the drivers involved in the alleged accident for a violation(s) of any statute, law, ordinance or regulation and if so, describe.
18. If there was any physical evidence of the alleged accident at the scene, describe what it was and where it was located in relation to the curb lines or other significant landmarks.
19. If after the alleged accident, there were any skid marks or yaw marks remaining on the roadway, describe their dimensions (length and width) and identify the motor vehicle which created the markings.
20. If a Police investigation was conducted, state the control number, the incident number and/or the report number, thereof.
21. If you (or your operator) appeared before any Traffic Court, Municipal Court or District Court, state the date and location and whether testimony was offered.
22. Do you admit that you (or your operator) were negligent in the operation and/or control and/or entrustment of a motor vehicle at the time of the alleged accident?
23. If you contend that Plaintiff was guilty of comparative/contributory negligence, then fully and specifically describe upon what conduct, acts or omissions of Plaintiff you base your contention.
24. If you and/or other occupants of your motor vehicle sustained any injuries in the alleged accident, state the nature of those injuries and identify any and all healthcare professionals you/they consulted and/or treated with.
25. If you have made any claim for benefits under the Pennsylvania Motor Vehicle Financial Responsibility Law, or any similarly applicable State Statute or Act, state:
(a) The name of the insurance company to whom the claim was submitted;
(b) The applicable claim number;
(c) The name of the individual at the company who supervised your claim;
(d) The total amount of healthcare professionals charges (i.e. medical bills) claimed;
(e) The total amount of wage-loss claimed;
(f) The total amount of any other economic losses and/or damages claimed (i.e. property damage);
(g) The total amount of healthcare professionals charges, wage loss and/or other economic losses and/or damages actually paid pursuant to such law, Statute or Act.
26. If you made any claim, or you contemplate making any claim, for damages and/or losses sustained as a direct result of the alleged accident, state the damages and/or losses claimed, the insurance carrier to whom such claim was made and the Commonwealth or State, County, Court, Term and Number of any lawsuit filed in this regard. If the matter was amicably resolved (i.e. settled), identity with whom and for what amount of compensation.
27. If you have engaged, or expect to engage, healthcare professionals and/or other expert witnesses (i.e. accident reconstructionists), whom you intend to have testify at trial on your behalf on any matter pertaining to this action, state:
(a) The name of the expert;
(b) The expert's professional address;
(c) The expert's occupation;
(d) The expert's specialty;
(e) The expert's qualifications (i.e. Curriculum Vitae);
(f) The topic or subject matter upon which the expert is expected to testify;
(g) The substance of the facts to which the expert is expected to testify;
(h) The substance of the opinion to which the expert is expected to testify;
(i) A summary of the grounds or foundation for each opinion the expert is expected to testify.
28. If you have engaged, or expect to engage, healthcare professionals and/or other expert witnesses (i.e. accident reconstructionists) for opinion(s), either oral or written, whom you do not intend to have testify at trial on your behalf, please state:
(a) The name of the expert;
(b) The expert's professional address;
(c) The expert's occupation;
(d) The expert's specialty;
(e) The expert's qualifications (i.e. Curriculum Vitae);
(f) The topic or subject matter of the expert witness' oral or written report;
(g) The location of and/or whom has the care, custody, possession and/or control of the expert witness' oral or written report, made to anyone other than yourself (i.e. an insurance company) providing an identity and address.
29. If you, your attorney or any representative of yours, conducted any sound, photographic, motion picture film, personal sight or any other type of surveillance of the Plaintiff(s), state:
(a) By whom (name and address of company and individual);
(b) The date(s) of such surveillance;
(c) The time(s) of such surveillance;
(d) The location(s) of such surveillance;
(e) The method by which such surveillance was made;
(f) A summary of what such surveillance reveals.
30. State the name, home and business addresses of the following:
(a) Those who actually witnessed the alleged accident;
(b) Those who were present at or near the scene at the time of the alleged accident;
(c) Those who have any knowledge or information as to any facts pertaining to the circumstances and/or manner of the happening of the alleged accident and/or the nature of the injuries sustained in the alleged accident.
31. At the time of the alleged accident or immediately thereafter, did you (or your operator) have any conversation(s) with or make any statement(s) to any of the parties or witnesses, or did any of them make any statement(s) to you or in your presence. If so, state the substance of any such conversation(s) or statement(s) and identify in whose presence it/they occurred.
32. State the name and address of the person answering these Interrogatories and their relationship with the Defendant.
_________________
Name of Attorney
Attorney for Plaintiff(s)
Identification No.:
Address
Telephone No.:
Fax No.:
e-mail:I ______ , subject to the penalties of 18 Pa.C.S.A. § 4904, relating to unsworn falsification to authorities, state the attached answers and/or documents are submitted in response to the foregoing Interrogatories and/or Requests for Production of Documents and that to the best of my knowledge, information and belief they are true and complete.
_________________
Signature
EXHIBIT ''B''
FIRST JUDICIAL DISTRICT OF PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF PHILADELPHIA COUNTY
PLAINTIFF'S NAME : Civil Trial Division : : Compulsory Arbitration : Program vs. : : ______ Term, 20 : DEFENDANT'S NAME : No. ______
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 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 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 (i.e. pedestrian, bicycle, etc.).
1. State:
(a) Your full name (maiden name, if applicable), alias(es), date of birth, marital status (name of spouse) at the time the cause of action and currently, residence and business addresses at the time the cause of action arose and currently and Social Security Number.
(b) Identify all other persons residing at your address at the time of the alleged accident;
(c) Identify all persons, by name and address, who had motor vehicles registered to the address you resided at, at the time of the alleged accident.
2. Identify, by name and address, at the time of the alleged accident and currently, the driver and owner of your motor vehicle involved in the alleged accident, and state:
(a) The date of issuance and each Commonwealth or State in which the driver has been licensed to operate a motor vehicle;
(b) Any and all restrictions on any of the aforementioned driver's license(s). If corrective lenses were required, state whether or not you (or they) were wearing them at the time of the alleged accident;
(c) Whether any such license(s) have ever been suspended or revoked, and, if so, when, where, by whom and the reason(s) therefore;
(d) The nature, extent and duration of any physical and/or mental defects you suffered from at the time of and prior to the alleged accident.
3. Identify all Commonwealths or States in which you were the registered owner of a motor vehicle on the date of the alleged accident. Identify the financial responsibility upon such motor vehicles, as defined by 75 Pa.C.S. Section 1702.
4. State in detail the manner in which the alleged accident occurred, specifying the speed, position, direction and location of each motor vehicle involved, just before, at the time of, and immediately after the alleged accident.
5. 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.
6. Describe the streets or other byways involved in the alleged accident, as follows:
(a) In terms of traffic lanes (i.e. parking, travel, turn-only lanes), the width of the streets or other byways;
(b) Type of road surface (i.e. concrete, black top, dirt, gravel, etc.);
(c) Roadway surface condition(s) (i.e. dry, wet, muddy, etc.);
(d) Any defects in the roadway which you believe contributed to the happening of the alleged accident.
7. State:
(a) In which lane the respective motor vehicles were traveling before the alleged accident and in which lane the alleged accident occurred;
(b) When you first observed the other motor vehicle involved in the alleged accident, stating the distance at that moment from the ultimate point of contact and the respective speeds of the motor vehicles at that time;
(c) The speed of your vehicle;
(1) At 100 feet from the point of contact;
(2) At 50 feet from the point of contact;
(3) At the point of contact.
(d) Whether your (or your operator's) view was clear, or what obstruction, if any, existed at the time of the alleged accident;
(e) What you (or your operator) did in an attempt to avoid the alleged accident;
(f) The exact point of contact of the motor vehicles, in terms of distance from the various curb lines or other significant landmarks and their final resting positions;
(g) Whether the responding and/or investigating police officers cited any of the drivers involved in the alleged accident for a violation(s) of any statute, law, ordinance or regulation and if so, describe.
8. Describe any and all damage to the motor vehicle in which you were an occupant or driver as a direct result of the alleged accident.
9. Identify the person and/or company who repaired and/or evaluated your motor vehicle to prepare a repair estimate.
10. 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.
11. State your address of departure and intended destination during your route of travel at the time of the alleged accident.
12. State the name, home and business address of the following:
(a) Those who actually witnessed the alleged accident;
(b) Those who were present at or near the scene at the time of the alleged accident;
(c) Those who have any knowledge or information as to any facts pertaining to the circumstances and manner of the happening of the alleged accident or the nature of the injuries sustained in the alleged accident.
13. List by company name, claim address and policy number(s) all policies of motor vehicle and/or health/medical insurance (including HMOs and health and welfare funds) providing coverage to you on the date of the accident for any portion of your injuries/damages which you contend are related to the accident. Provide copies of the ''declaration sheets'' of all such policies in your possession, custody and/or control. With respect to any motor vehicle policy issued in the Commonwealth of Pennsylvania, indicate your Tort Option selection (i.e. ''Full Tort'' or ''Limited Tort'').
14. State all economic as well as non-economic damages and/or loses you believe you sustained as a direct result of the alleged accident. Describe in detail all injuries you sustained, including their nature, extent and duration.
15. State:
(a) The identity, by name and address, of each hospital or university medical center where you were examined and/or treated and whether you were admitted;
(b) The identity of any person(s) who examined, evaluated or treated you, noting their name, address and specialty;
(c) The identity, by name and address of any diagnostic test center that provided services and what test were performed;
(d) The date(s) of all examination(s), evaluation(s), treatment(s) and/or confinement(s) by healthcare professionals and their corresponding charges.
(e) Identify any healthcare professional(s) you are currently consulting and/or treating with for any of the injuries and/or damages you sustained as a direct result of the alleged accident and what symptoms you still allegedly suffer from.
16. If you contend that the alleged accident aggravated a pre-existing condition(s), state:
(a) The nature and extent of such pre-existing condition;
(b) The date upon which you believe you recovered from symptomatology of the pre-existing condition(s), prior to the accident date;
(c) The name and address of the healthcare professional(s) who treated you for the pre-existing condition(s); and
(d) The date of and circumstances causing you to incur the pre-existing condition(s).
17. If you have fully recovered from the injuries you allege to have sustained in the present accident, state the approximate date you recovered. If you have not fully recovered from your injuries, then describe any pain, ailment, complaint, injury or disability that you allege you still suffer from as a direct result of the alleged accident.
18. State whether you sustained any injuries or suffered from any disease, deformity, or impairment, prior to or subsequent to the accident herein, which in any way affected those parts of your body claimed to have been injured as a direct result of the instant accident. If so, state:
(a) The nature and extent of any such injury, disease, deformity or impairment;
(b) The date of the occurrence or diagnosis of such injury, disease, deformity or impairment;
(c) The names and address(es) of the healthcare professional(s) you have consulted with and/or treated with and the corresponding dates thereof, for such injury, disease, deformity or impairment.
19. 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 (i.e. bonuses, overtime, etc.).
20. State the dates you have been absent from work since the date of the alleged accident for reasons relating to the injuries, damages and/or losses you sustained in the accident. If you have returned to your employment, state the date you returned and whether there had been any change in your stated title or position, accompanying duties and/or responsibilities and/or your wage, salary or supplemental wages and identify by name and address the employment you returned to.
21. Describe in detail any future lost wage claim and/or impairment of earning capacity and/or power you believe you will have as a direct result of the alleged accident and the basis thereof.
22. If you have ever been involved in any prior litigation as a party or witness, describe the nature of the lawsuit, the Commonwealth or State, County, court term and number of the lawsuit, as well as the outcome of the lawsuit, if you were a party thereto.
23. If you allege that the Defendant(s) violated any Statute, law, ordinance or regulation which contributed to the happening of the alleged accident, cite the Title and Section of said law and describe the basis for such allegation.
24. If you have engaged, or expect to engage, healthcare professionals and/or other expert witnesses (i.e. accident reconstructionists), whom you intend to have testify at trial on your behalf on any matter pertaining to this action, state:
(a) The name of the expert;
(b) The expert's professional address;
(c) The expert's occupation;
(d) The expert's specialty;
(e) The expert's qualifications (i.e. Curriculum Vitae);
(f) The topic or subject matter upon which the expert is expected to testify;
(g) The substance of the facts to which the expert is expected to testify;
(h) The substance of the opinion to which the expert is expected to testify;
(i) A summary of the grounds or foundation for each opinion the expert is expected to testify.
25. State whether you have been convicted of any crime(s) in the past ten (10) years, and if so, state the nature of such conviction.
_________________
Name of Attorney
Attorney for Plaintiff(s)
Identification No.:
Address
Telephone No.:
Fax No.:
e-mail:I ______ , subject to the penalties of 18 Pa.C.S.A. § 4904, relating to unsworn falsification to authorities, state the attached answers and/or documents are submitted in response to the foregoing Interrogatories and/or Requests for Production of Documents and that to the best of my knowledge, information and belief they are true and complete.
_________________
Signature
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