Colorado Plaintiff's Interrogatories to Defendant - Personal Injury

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This form is a sample set of interrogatories submitted by the plaintiff to the defendant in a personal injury case involving an automobile accident.

Colorado Plaintiff's Interrogatories to Defendant — Personal Injury are a crucial component of the legal process in personal injury cases. These interrogatories serve as a means for the plaintiff's attorney to gather relevant information from the defendant, aiding in the preparation of the case. Here is a detailed description of what these interrogatories entail: 1. Background: The plaintiff's interrogatories will typically begin by requesting basic background information from the defendant. This may include their full name, address, contact details, occupation, and any previous employment history relevant to the case. 2. Incident Details: A crucial aspect of personal injury cases is understanding the specifics of the incident that caused the plaintiff harm. Interrogatories will aim to gather detailed information related to the accident or event that led to the injury. This may involve questions about the date, time, location, weather conditions, and any witnesses present. 3. Liability: To establish liability, the plaintiff's interrogatories will often inquire about the defendant's actions leading up to and during the incident. These may include questions about any negligent, reckless, or intentional behavior exhibited by the defendant that resulted in the plaintiff's injury. 4. Medical Records and Treatment: Personal injury cases require the examination of the plaintiff's injuries and medical treatment received. Interrogatories will seek information regarding the defendant's knowledge of the injuries sustained, medical treatment sought by the plaintiff, previous injuries or medical conditions, and any medical professionals consulted. 5. Damages: In order to assess the extent of the damages caused to the plaintiff, interrogatories will delve into various aspects. They may require the defendant to provide information on property damage, medical expenses, lost wages or earning capacity, pain and suffering, and any other financial or non-economic losses suffered as a result of the incident. 6. Insurance Coverage: Interrogatories may also seek information regarding the defendant's insurance coverage, including policy limits and any other potentially applicable coverage, such as umbrella policies or additional named insureds. Types of Colorado Plaintiff's Interrogatories to Defendant — Personal Injury: 1. General Interrogatories: These are the foundational interrogatories that cover a broad range of topics related to the defendant, the incident, and its aftermath. They establish the preliminary basis for the case. 2. Specific Interrogatories: These interrogatories delve deeper into specific aspects of the case, such as the defendant's actions, their relationship to the plaintiff, or any relevant prior incidents involving the defendant. 3. Expert Witness Interrogatories: In cases where expert witnesses are involved, special interrogatories may be used to gather information regarding these witnesses and their opinions. 4. Damages Interrogatories: These interrogatories focus primarily on the damages suffered by the plaintiff. They aim to quantify the financial and non-economic losses, such as medical expenses, lost wages, pain, and suffering. In conclusion, Colorado Plaintiff's Interrogatories to Defendant — Personal Injury play a crucial role in personal injury cases. By meticulously gathering information about the incident, the defendant's actions, and the resulting damages, these interrogatories provide the necessary groundwork for a strong legal case.

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FAQ

They are provided for your information. There is no form for your answer, but you typically have to respond in a specified format, using paper with numbers down the left-hand side, with your name and address at the top left, the name of the court and of the case, and the case number.

If you are unable to answer an interrogatory because it is too vague, ambiguous, or somehow objectionable, you can state an objection and the reason for your objection. You must then answer to the extent the interrogatory is not objectionable.

Generally, interrogatories are objectionable if they seek information that is not within the scope of discovery as defined in Maryland Rule 402 or Federal Rule 26(b). These are typically requests that are not relevant, unduly burdensome, broad, vague, privileged. or protected by the work product doctrine.

You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.

There are two types of requests, Pattern and Non-Pattern. Pattern Interrogatories or Requests for Production of Documents are a set of questions or requests that are specifically outlined in the Colorado Rules of Civil Procedure. They are consistent and the same in every case.

Parties may object to these pattern interrogatories on grounds including, but not limited to, that the interrogatories exceed the scope of permissible discovery as defined in C.R.C.P. 26(b)(1) because the inquiry is not relevant to the claims and defenses of any party or is not proportional to the needs of the case.

In civil lawsuits in Colorado courts, written interrogatories are primarily governed by Colorado Rule of Civil Procedure (?C.R.C.P.?) 33 and each party is allowed to serve up to 30 written interrogatory requests on adverse parties; however, that number may be modified up or down for good cause. See C.R.C.P. 26.

Have your client verify the interrogatories. Federal Rule of Civil Procedure 33(b)(5) requires the attorney to sign the objections and the client to sign the answers.

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Colorado Plaintiff's Interrogatories to Defendant - Personal Injury