Interrogatory No. Interrogatory No. now; Height: 5' 7" and Weight: 175 lbs. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. 20: State your date of birth, social security number, and your height and weight, both now and at the time of the accident. $ 1,535.00 Keirston PT $ 8,332.00 Irfan Shafiq, M.D. ANSWER TO INTERROGATORY NO. The doctors' opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents. Upper Chesapeake Medical Center $ 780.08 Adallah J. Helou, M.D. The case settled and I got a lot more money than I expected. 7: State in detail the nature of all bodily injuries sustained by you as a result of the accident, and state which injuries, if any, are claimed to be an aggravation to any condition that existed before the accident. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents. Interrogatory No. Mathew B. Brady (May 18, 1822 – January 15, 1896) was an American photographer, and one of the earliest in American history. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents. Michele T. Cerino, M.D., is an expert in the field of thoracic surgery; she is expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. ANSWER TO INTERROGATORY NO. $ 1,515.00 John Cardero, D.O. $ 760.00 Advanced Radiology $ 4,101.00 Maryland General Hospital $ 1,100.00 Prescriptions (CVS) $ 43.97 TOTAL MEDICAL EXPENSES $117,985.32. We serve the following localities: Baltimore; Prince George's County including Bowie, Laurel, Landover, Hyattsville; Anne Arundel County including Glen Burnie; Baltimore County including Cockeysville, Glyndon, Hunt Valley, Jacksonville, Lutherville-Timonium, Owings Mills, Parkville, Reisterstown, Plaintiff Attorney Legal Information Center, Example Pretrial Documents for Plaintiff's Lawyers. 13: Did you lose any time from employment as a result of the injuries sustained in this accident? I hereby certify that a copy of the foregoing has been sent via U.S. Mail, first-class, postage prepaid, on the 25th day of July, 2018, to: Nationwide Insurance 8600 LaSalle Road The Oxford Building, Suite 620 Towson, MD 21286-5955, Respectfully submitted, Miller & Zois, LLC, (410)779-4600 (410)760-8922 (fax) Attorneys for the Plaintiff, Sample Plaintiff's Answers to Defendant's Interrogatories | Maryland Personal Injury Lawyers. 18: Plaintiff was in a car accident in the late 1980's or early 1990's when Plaintiff injured back. 2: Identify all eyewitnesses and the location of each at the time of the accident. 4: Trooper Wheeley of the Maryland State Police arrived on the scene within two hours of the occurrence. $ 1,950.00 Constantine A. Misoul, M.D. The doctors' opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. 19: State whether you ever had, before the accident, complaints of pain or symptoms of disease or injury in those parts of your body which were injured in the accident. $ 1,065.00 (MS DOCTORS: $ 8,409.00) Steven A. Romener, M.D. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents. She does have pain in her legs on occasion. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. $ 3,098.92 Michele T. Cerino, M.D. Interrogatory No. She also have headaches. ANSWER TO INTERROGATORY NO. The doctors' opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. Additionally, any probative value would be outweighed by the prejudicial affect. The entire team from the intake Samantha to the lawyer himself (Ron Miller) has been really approachable. $ 140.00 Rafiq K. Patel, M.D. Representatives and doctors from Upper Chesapeake Medical Center are experts in the field of emergency medicine; the representatives are expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. Representatives and doctors from Good Samaritan Hospital are experts in the field of general medicine; the representatives are expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. This is the OLD TIME MOVIE section. I had a couple of months of physical therapy and had a complete recovery. The American television series The Love Boat (Love Boat in its final season), set on a cruise ship, was aired on ABC from September 24, 1977 until May 24, 1987. These was another individual at the scene as identified above. Best known for his scenes of the Civil War, he studied under inventor Samuel F. B. Morse, who pioneered the daguerreotype technique in America. Plaintiff's family physicians are Dr. Linder and Dr. Summer, her gynecologist is Dr. Kulkarni. Interrogatory No. Interrogatory No. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. 27: Not to Plaintiff's knowledge. If so, state the details, including date, place of such accidents or accident, nature of injuries sustained, and identify the parties involved, stating the identities of attending physicians and other health care providers, and dates of all examinations or treatments for such injuries. If so, state the date, the subject matter, the identity of the person recording said testimony, and the identity of the person who has present possession of each said transcript of testimony. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. If so, please indicate which of the above, the date thereof and the identities of the persons who procured the same, and the identities of the persons having possession of the same. At the time of the accident, I was not taking any medication. 25: Objection as to relevance. Please do not include any confidential or sensitive information in a contact form, text message, or voicemail. Interrogatory No. 3: Identify all persons who were at or near the scene. Interrogatory No. Joel D. Formosa, M.D., is an expert in the field of orthopaedic surgery; he is expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. Le TOP 10 des AMÉRICAIN et les 1000 américain et américaine célèbres du 1er Cimetière du Web : tombes, biographies, photos, vidéos... ainsi que les personnalités les plus populaires du moment. 20: DOB: 1/20/67; SSN: 215-88-8720; Height: 5' 7" and Weight: 163 lbs. 13. If the vehicle is unrepaired, state the address and the hours at which time it may be seen. 5: Identify all persons who have given you statements, or from whom you have statements reduced to written or recorded form, the dates of such statements, the identity of persons who procured such statements, and the identities of the persons who have custody or possession of such statements. Gary was a two tour Vietnam Veteran. Plaintiff was not running late at the time of the accident. There are now search engines like the one above installed on the Front Door Page and the Main Library Page to make finding your favorite shows easier. He was a loving, caring man that worked hard and spent most of his adult life in the carpentry business. Kevin Strauss or some other individual will be called as an expert in the field of vocational rehabilitation; they are expected to testify as to the extent of the Plaintiff's ability to be re-trained in a career suitable to her skills and ability to learn a new trade, and the costs associated with such retraining, loss of earnings capacity and any losses she may incur. 6: Plaintiff's attorney is in possession of photographs of the damage to her vehicle and photographs following her thoracic outlet surgery. 24: Outline in detail the work schedule, physical and other activities for the Plaintiff(s), for the 24-hour period immediately before the accident. ANSWER TO INTERROGATORY NO. Ron helped me find a clear path that ended with my foot healing and a settlement that was much more than I hope for. Henry A. Spindler, M.D., is an expert in the field of rehabilitation medicine and electromyography; he is expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. The doctors' opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. Interrogatory No. $ 8,875.00 Rosen-Hoffberg Rehabilitation $ 3,600.85 And Pain Management Assoc., P.A. 35,000 individual programs available including episodic TV shows, specials, and Short Format and Feature length films. Interrogatory No. (b) The word usage and sentence structure is that of the attorney and does not purport to be the exact language of the executing party. and Towson; Carroll County including Westminster; Frederick County including Frederick; Harford County including Abingdon, Bel Air, Belcamp, and Forest Hill; Montgomery County including Germantown and Rockville; Howard County including Ellicott City and Columbia, Washington, D.C. and Washington County including Hagerstown. The doctors' opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents. She has scarring from her thoracic outlet surgery and her neck surgery, she also has a limited range of motion in her neck due to the hardware from the surgery. Ron even fought to reduce how much I owed in medical bills so I could get an even larger settlement. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. Advanced Radiology; Joe Kennedy, M.D. Rakesh K. Mathur, M.D., is an expert in the field of internal medicine, anesthesiology, and critical care; he is expected to testify at trial as to the care and treatment rendered to the Plaintiff following the auto accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. Le TOP 10 des ACTEUR et les 1000 acteur et actrice célèbres du 1er Cimetière du Web : tombes, biographies, photos, vidéos... ainsi que les personnalités les plus populaires du moment. Plaintiff was a little sore from the accident and had a couple of physical therapy visits and was back to baseline shortly thereafter. 1: Give a concise statement of facts as to how you contend the accident took place. The contact form sends information by non-encrypted email, which is not secure. Hopefully I won't need it again but if I do, I have definitely found my lawyer for life and I would definitely recommend this office to anyone! 1: On May 22, 2003 Plaintiff was operating her vehicle on Maryland Route 152 near its intersection with Reckord Road. Gertrude Jones, Norman Mailer, and William Phillips are personal friends who can testify as to her injuries, pain, and suffering. 19: State whether you ever had, before the accident, complaints of pain or symptoms of disease or injury in those parts of your body which were injured in the accident. Legacy.com enhances online obituaries with Guest Books, funeral home information, and florist links. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. This final installment of the Netflix rom-com trilogy is earnest, bright-eyed and without a hint of cynicism. Interrogatory No. If so, state when, describe the complaints or symptoms, and identify all doctors and other health care providers who treated or provided examinations or treatments. Representatives and doctors from Franklin Square Hospital; including, Lawanda Summers, M.D., Edward Carter, M.D., are experts in the field of emergency medical treatment; their representatives are expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. 4: Identify all persons who arrived at the scene within two (2) hours after the accident. Interrogatory No. If a married woman, state your full maiden name. + de 10 000 célébrités, stars et personnalités du monde entier avec leur biographie, des photos, des questions/réponses sur leur vie, des commentaires d'internautes ainsi que leurs … 7: As a direct and proximate result of the Defendant's negligence, Plaintiff sustained injuries to her neck, back, knees, head, thoracic outlet syndrome, radiating numbness, tingling and pain into her upper and lower extremities, a herniated cervical discs requiring a discectomy and fusion at three levels. Interrogatory No. 21: State the itinerary of your vehicle for the four (4) hours prior to the accident, including the time and place of the beginning of the trip, the time and duration of each stop, the place of destination, and the expected time of arrival. Plaintiff was a little sore from the accident and had a couple of physical therapy visits and was back to baseline shortly thereafter. ANSWER TO INTERROGATORY NO. ANSWER TO INTERROGATORY NO. ; and representatives are experts in the field of interpretation of diagnostic testing; the representatives are expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. 8: See Answer to Interrogatory #15 and records produced by Plaintiff. Gray, 6o, of Bryant Pond died April 1, 2009 after a brief illness. Brady opened his own studio in New York in 1844, and photographed Andrew Jackson, John Quincy … Les traumatismes, comme les accidents et le suicide, sont les causes de décès prédominantes chez les hommes de moins de 40 ans. 9: See Answer to Interrogatory No. Plaintiff does not recall doing anything unusual the night before the accident. CHiPs (TV Series 1977–1983) cast and crew credits, including actors, actresses, directors, writers and more. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. ANSWER TO INTERROGATORY NO. The doctors' opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. 14: State the amount reported as earned income in your Income Tax Returns for each of the past five (5) years, and the district in which the Returns were filed, and attach copies of Federal and State Income Tax Returns for the past five (5) years. Specify in which category each such person has knowledge. The doctors' opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. Representatives and doctors from Chesapeake Medcare Services are experts in the field of pain management; the representatives are expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. She will be making a claim for future loss of earning capacity. The doctors' opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. Interrogatory No. $ 2,400.00 Good Samaritan Hospital $60,100.00 Henry A. Spindler, M.D. 13: Yes. 23: State what part of your vehicle was damaged, and if it was repaired, the identity of the person who performed such repairs, the dates of such work, and the cost thereof. ANSWER TO INTERROGATORY NO. 27: As to any document, object, or other item produced by you in this case which has been altered prior to or as a part of the production process, state its identity with sufficient specificity to identify it, the nature of each alteration (i.e., the material or condition prior to alteration and the material or condition after the alteration), the date of each alteration, the name and address of each person who made each alteration and the reason or purpose of each alteration. 11: If you have any present complaints on account of the injuries received in the accident, state in detail the nature of the present complaints, and what injuries, if any, are alleged to be permanent. Interrogatory No. Schalizki, Newon and Haggerty are other last names I have had. Interrogatory No. The doctors' opinions are based upon their review of Ms. Powers’ medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. ANSWER TO INTERROGATORY NO. 24: Within the 24 hours prior to the accident Plaintiff was at work the day of the accident and the day before. If so, state precisely the dates of absence from employment, the amount of wages lost on account thereof, and the identities of the employers from whom said wages or income would have been received, and state whether or not there is a continuing wage loss or a diminished income. Nothwithstanding this objection, Plaintiff has not been convicted of a crime. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents. 18: State specifically whether you received any injuries in any accident or occurrence before the accident described in the pleadings, or after it. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents. ANSWER TO INTERROGATORY NO. 17: State whether you have within your control, or have knowledge of any transcripts of testimony in any proceeding arising out of the accident. Plaintiff saw Dr. Linder on 7/23/03, the day after the accident. 12: 2004 Riverview Nursing Center 2005 Riverview Nursing Center 2006 Riverview Nursing Center 2017 Canton Harbor Healthcare Center. Representatives and doctors from Rosen-Hoffberg Rehabilitation and Pain Management Associates are experts in the field of medical rehabilitation, physical therapy, and pain management; the representatives are expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. 9: Identify all physicians and institutions which have examined and treated you for any cause for the past five (5) years, and the dates and nature of such treatment. Avraam Karas, M.D., is an expert in the field of orthopaedics and thoracic and outlet surgery; he is expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. 15: Give an itemized statement of all expenses paid or incurred by you as a result of the accident, except for lost wages set forth in Answer to Interrogatory No. 11: She still continues to have complaints of pain in her neck, back, and arms. Mid-Atlantic Neurosurgical Associates, P.A., Agha S. Khan, M.D., and their representatives are experts in the field of orthopedics and neurosurgery; the representatives are expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. Attach hereto a copy of any signed statement, or a recorded statement, under your control, made by the Defendant(s), or the Defendant's agent or employees. The doctor’s opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. Plaintiff sprained her ankle in 1996 and was out of work for a couple of days but had a complete recovery. Interrogatory No. Representatives and doctors from Harford County Ambulatory Surgical Center are experts in the field of pain management; the representatives are expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. ANSWER TO INTERROGATORY NO. Interrogatory No. Interrogatory No. At the time of the accident, Plaintiff was earning $36.00 an hour and worked an average of 32 hours a week. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. Abdallah J. Helou, M.D., is an expert in the field of orthopedics and thoracic outlet surgery; he is expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. 3: Immediately after the accident, Plaintiff, her son and the Defendant were present at the scene of the accident, thereafter, the Defendant left the scene. Lewiston-Gary A. ANSWER TO INTERROGATORY NO. Interrogatory No. Interrogatory No. $ 1,475.00 Agha S. Khan, M.D. 22: Within (8) hours prior to the accident I did not consume any alcoholic beverages. Indiana Area School District © 2021. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff's response to request for production of documents. They quite literally worked as hard as if not harder than the doctors to save our lives. Thomas Bonery is an expert in the field of economics; he is expected to testify as to the present day value of Plaintiff's loss of earning capacity and future lost wages. The doctors' opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. Tous les décès depuis 1970, évolution de l'espérance de vie en France, par département, commune, prénom et nom de famille ! ANSWER TO INTERROGATORY NO. Mission Statement - To provide supportive and engaging educational experiences that prepare students to be productive citizens who positively impact society. Columbo (TV Series 1971–2003) cast and crew credits, including actors, actresses, directors, writers and more. ANSWER TO INTERROGATORY NO. Richard Trinkes, M.D., is an expert in the field of orthopaedics; he is expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. Gary A. The Plaintiff has been unable to return to work in her capacity as a Licensed Nurse Practitioner since the accident. Interrogatory No. It cost approximately $8,000.00 to repair the vehicle. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future.