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If you are reading this post, you have probably received a letter or email from me with a document attached called Interrogatories. This happens in every personal injury case – and almost every other lawsuit of any kind.

Please read this post over and call me if you have any questions.

What are Interrogatories?

It just means “questions” but we attorneys have to use fancy names for everything!

When a lawsuit starts out, the two sides engage in a process called “discovery” where each side tries to find out what the other side is going to say and do at trial.

The first step in that process is sending interrogatories. These are formal written questions that we have answer in a formal written manner.

I will take care of drafting the formal answers. I usually know most of the information they ask – because it is about your case. In fact, in most personal injury cases the questions are pretty standard and I know what is coming. You will have to sign these formal answers when I prepare them.

But they always ask some questions I do NOT necessarily know the answers to. Most of these involve your past history. So, I always send you the interrogatories (probably attached to an email as a pdf document) and I ask that you give me the answers to some of the questions.

What do I have to do?

Look at the interrogatories I sent you (usually attached to the email as a pdf document) and follow the instructions in my email. I will tell you not to worry about some (because I know the answers) and I will ask you details about others.

Get me the answers to those questions I circled. I prefer written answers so there is no confusion and no mistakes. Also, your written answers now will be great for my trial prep later! The best way to do this is with a simple Word document or reply to the email I sent you with the interrogatories attached. I don’t need anything fancy. I just need the information.

I do prefer written answers. If you don’t write the answers for us, my staff will call you and go over the questions. But that is not as accurate or complete.

At least think about these questions now and be ready for that phone call.

Do you need documents?

Maybe. If so I told you in my email or we will call you.

The other piece of this written discovery process (in Circuit Court cases) is called “Requests for Production of Documents.” Usually I have all of this stuff so I don’t need anything from you. But if we don’t have something, I will need you to get it for me.

Common documents I need are:

  • Tax returns. If we are making a lost wage claim, opposing counsel gets your tax returns for the 3 years prior to the accident, and every year since then. They may ask for more but I may limit them to this number of years.
  • Any records or diagnostic films from past medical treatment before the accident. Do you have any of your old medical records? If so, get them to me.
  • Repair records for your car from the few months before the accident – if there are any. If your care was in perfect working order the month or two before the accident, ignore this.

Review & Signature

When we have prepared your formal answers, you have to review them and sign them. That will be a formal meeting in my office. We can easily make any changes at that meeting if we have not answered something correctly.

If you are not in Southern Maryland we can do this via mail or email and phone or Zoom. But it is a LOT better to have you come into the office to discuss these formal answers before signing them.

What is my time limit?

One week please. Two weeks at the most.

Under the Maryland Rules of Civil Procedure, I need to answer these questions in 30 days (15 days in a District Court case). I can usually get an extension from opposing counsel, so that is sort of a “soft” deadline.

But I would like you to get me answers in one week if at all possible – in two weeks at most. Then we have time to prepare the formal answers and get you in to review and sign them before the deadline.


As always, please contact me if you have any questions or concerns. And we will be in touch soon to go over those questions and schedule your meeting to sign them.

Want to know more? Discover what you need to know about Maryland car accident cases. Click here to see our Free Legal Consumer Guide to Car Accident Cases and get answer to your questions today.

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