What is an Interrogatory in a Personal Injury case?

The practice of Personal Injury can be complicated and lengthy. There are many components even before trial, that are essential in obtaining a satisfactory judgment. Here at PereGonza, we do not settle for satisfactory, and we fight tooth and nail to protect our client’s interests.
One of the most important steps in a Personal Injury case is discovery. During discovery, both parties to the lawsuit have an opportunity to build evidence that favors their position. One method of obtaining such evidence is called Interrogatories.

What is an Interrogatory in a Personal Injury case?
In a Personal Injury case, interrogatories are written questions that one party asks the opposition in order to gather important evidence, relevant to each party’s case. Interrogatories are governed by Florida Rules of Civil Procedure § 1.340. Pursuant to Rule 1.340, party can send a maximum of thirty (30) interrogatories, and the party whom the interrogatories are directed must answer and provide any objections within thirty (30) days of the service.

What Are Common Interrogatories Asked in a Florida Personal Injury Case?
Interrogatories are used to narrow disputed issues and prepare the parties for further discovery. For example, many lawyers utilize interrogatories to acquire basic information to use in a deposition.

Some of the common questions asked by parties are as follows:
• What type of injuries are you claiming?
• Are you filing a claim for lost wages? If so, how much in lost wages are you claiming?
• List all medical treatment you have received since the accident.
• List all medical treatment you have received in the 10 years prior to the accident.
• Are you aware of any witnesses to the accident?
• In your own words, please state how the accident occurred.
• List all medications you were taking at the time of the accident.
• Have you ever been married? If so, state the dates of all marriages and the contact information for each spouse and ex-spouse.
• List all jobs you have ever held since the age of 18, salary, and how long you worked there.

At first glance, these questions may seem intrusive and extremely personal. Nevertheless, Courts have allowed such inquiry to determine the disputed facts and any prior history that may be relevant to the case. Therefore, it is of utmost importance to answer each of the questions truthfully and to the best of your ability.

Why are Interrogatories Important?
Interrogatories allow parties to narrow the facts and resolve any disagreements that may arise from a lack of evidence. A good lawyer will be able to utilize interrogatories to your benefit. Therefore, it is important to hire attorneys well versed in litigation strategies, and the complexities of Personal Injury.