IN THE ___________________________________________
JANE DOE :
Plaintiff : CASE NO.:
v. :
WASHINGTON METROPOLITAN :
AREA TRANSIT AUTHORITY :
Defendant :
:
:
:
:
PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT WASHINGTON
COMES NOW, the Plaintiff, Jane Doe, by and through counsel, and files with the Clerk
the following First Set of Interrogatories to be answered by the Defendant, Washington
Metropolitan Area Transit Authority within thirty days (30) days after service pursuant to MD
Rules, Rule 2-421.
METRAPOLITAN AREA TRANSIT AUTHORITY
Definitions and Instructions
A. In accordance with Rule 2-421(b), your response shall set forth the interrogatory, and
shall set forth the answer to the interrogatory “separately and fully in writing under oath”
or “shall state fully the grounds for refusal to answer any interrogatory.” This response
shall be signed by you.
B. In accordance with Rule 2-421(b), your answers “shall include all information available”
to you “directly or through agents, representatives, or attorneys.”
C. Pursuant to Rule 2-401(e), these interrogatories are continuing in nature so as to require
you to file supplementary answers if you obtain further information before trial.
D. Pursuant to Rule 2-421(c), if you elect to specify and produce business records of yours
in answer to any interrogatory, your specification shall be in sufficient detail to enable the
interrogating party to locate and identify the records from which the answer may be
ascertained.
E. Where the name or identity of a person is requested, please state his or her full name,
phone number, home address, business address, if known.
F. Unless otherwise indicated, these interrogatories refer to the time, place, and
circumstances of the occurrence mentioned or complained if in the pleading.
G. Where knowledge or information in possession of a party is requested, such request
includes knowledge of the party’s agent, representatives, and unless privileged, his
attorney(s). When answer is made by a corporate Defendant, state the name, address, and
title of the person supplying the information and making Affidavit and the sources of his
information.
H. The pronouns “you” and “your” refer to the party to whom these Interrogatories and
Requests for Production of Documents are addresses and the persons mentioned in
Clause D.
I. “Documents” and “things” mean any written, recorded, or graphic matter, however
produced or reproduced, and whether or not claimed to be privileged against discovery on
any ground, including, but not limited to, reports, records, lists, memoranda, telegrams,
correspondence, “E-mail”, schedules, photographs, videotapes, sound records, microfilm,
microfiche, films, and information stored in computers or other data or word processing
equipment at any other tangible objects.
J. If any document or thing is omitted or not produced because of a claim of privilege,
identify the date, author, and addressee of the document and the basis of the claimed
privilege.
Interrogatories
1. Provide your agent(s), servant(s) and/or employee(s) full name, address, social
security number, date of birth, and other names or aliases he/she has ever used or
been known by, who operated access metro bus on July 15, 2015, and in which the
Plaintiff was a passenger.
ANSWER:
2. Describe your agent(s), servant(s) and/or employee(s), who was operating Metro Bus,
duties and hours worked for the time period of week June 13, 2015.
ANSWER:
3. Detail all jurisdictions that your agent, servant and/or employee is or has ever been
licensed to drive in, and all jurisdictions she/he has been licensed to operate metro
access bus in. Provide the driver’s license number, date of licensure, and describe the
current status of each such license and whether any negative action including
revocation, suspension, withdrawal, or any other restriction) has ever been taken om
any such license.
ANSWER:
4. If your agent, servant and/or employee, the operator of the said Metro Bus, consumed
an alcoholic beverage, drugs (prescriptive or otherwise), and/or medication within 24
hour period immediately before the accident, or if you were required to take any
medication within twelve hour period immediately before the collision, state the
nature thereof, the purpose thereof, the name and address of the doctor who
prescribed the medication, if any, and dosage prescribed, the amount taken or that
was to be taken within such period. As to alcohol, the amount consumed, when and
where consumed, and identify all person present during such consumption.
ANSWER:
5. State whether at any time during the fifteen year period preceding the date of your
answers to these interrogatories, your agent, servant and/or employee has been
convicted of any crime including traffic offenses. If so, for each conviction identify
the court in which he/she was convicted and state the amount of any fine and the date
and length of any incarceration imposed. For purposes of this interrogatory, a
conviction includes a plea of nolo contendere followed by a sentence, whether or not
the sentence is suspended.
ANSWER:
6. State whether there exists any protocols, procedures, guidelines, standards, or policy
manual(s) to govern or guide your agents, servants and/or employees, such as drivers
of Metro Bus, in the exercise of their duties on July 15, 2015.
ANSWER:
7. If the above Interrogatory is answered in the affirmative, state whether your agents,
servants, and/or employees followed these protocols, procedures, guidelines,
standards, or policy manual(s) in the exercise of their duties on or about July 15,
2015.
ANSWER:
8. Identify each manager, supervisor, operators, driver, dispatcher, receptionist,
secretary and other employee, agent, and/or servant who was on duty within the 48
hour period prior to and after the accident who had any interaction or supervisory
responsibilities with the Metro Bus driver who transported the Plaintiff, indicating the
nature of your relationship (i.e. agent, servant, and/or employee) with each such
person, job position and duties at the time f the occurrence and at present.
ANSWER:
9. Describe all written and verbal statements given by you, your employees, agents,
servants, representatives or witnesses regarding the accident involving the Plaintiff.
ANSWER:
10. Give a complete statement of the facts as to how you contend that the occurrence took
place including the exact location of the occurrence, the direction in which all
operators were proceeding, and the speed at which all operators were proceeding.
ANSWER:
11. Identify all written communication, including internal minutes of all meetings and
notes therefrom, subsequent to the accident and/or the driver of the Metro Bus who
transported the Plaintiff, regarding safety procedures and vehicle operations at
WMATA.
ANSWER:
12. If a report about this occurrence was made by you or your agent servant or employee
in the ordinary course of business, including, but not limited to, an accident report or
quality assurance report, provide the date of each report and identify the person(s)
who made each report and the person(s) who presently have custody of each report.
ANSWER:
13. Identify each person who has given you or your agents, servants and/or employees a
signed, written, taped recorded or oral statements concerning the circumstances of
this case, including the names, addresses and telephone numbers of each such person.
ANSWER:
14. Identify the Metro Bus vehicle, along with vehicle identification number (VIN), in
which the Plaintiff was a passenger on July 15, 2015.
ANSWER:
15. If it is your contention that Plaintiff’s injuries on July 15, 2015 were caused in whole
or in part by some person or persons other than your agents, servants and/or
employees, please identify each such person and act or omission.
ANSWER:
16. Identify every person and their last known address not otherwise identified in your
Answers to these Interrogatories, including eyewitnesses to all or part of the
occurrence, who has personal knowledge of any facts material to this case and
generally describe or summarize these facts each person possesses which are material
to this claim.
ANSWER:
17. State the substance of all discussions concerning the occurrence that you or your
agents, servants and/or employees or others in your presence had with any party to
this case. State when and where each discussion took place and identify all persons
who were present.
ANSWER:
________________________
Attorney’s Name, Bar#
Attorney for Plaintiff/Defendant
Address
Phone
