This form is a sample set of interrogatories and requests for production propounded to plaintiff by the defendant in a personal injury action.
New Mexico First Interrogatories and Requests for Production to the Plaintiff by the Defendant — Personal Injury are legal documents in a personal injury case filed in New Mexico. These documents are used by the defendant's attorney to gather information and evidence from the plaintiff to build their defense. Below are different types of New Mexico First Interrogatories and Requests for Production to the Plaintiff by the Defendant — Personal Injury: 1. Interrogatories— - General background: The defendant's attorney may request the plaintiff to provide personal information, employment history, medical history, and other relevant background information that could potentially impact the case. — Accident details: The defendant may seek specific information about the circumstances of the accident, including the location, date, time, weather conditions, and any witnesses present. — Injuries and medical treatment: These interrogatories focus on the plaintiff's injuries sustained in the accident, medical treatments received, medical providers consulted, past medical history, and current health conditions. — Financial losses: The defendant's attorney may inquire about the plaintiff's financial losses, including medical expenses, lost wages, property damage, and any other related costs incurred. — Insurance coverage: Interrogatories may ask about the plaintiff's current and past insurance coverage, including health insurance policies, automobile insurance, and any other relevant policies. — Previous legal actions or claims: The defendant may request information about any previous legal actions, lawsuits, or claims the plaintiff has filed or been involved in. — Witness identification: The defendant's attorney may require the plaintiff to identify potential witnesses who might have information or observed the accident. 2. Requests for Production: — Medical records: The defendant may ask the plaintiff to produce all relevant medical records, including hospital records, doctor visits, surgeries, prescriptions, and any other treatment related to the injuries claimed. — Employment records: The defendant's attorney may request the plaintiff's employment records, including pay stubs, tax forms, and other documents related to income and employment history. — Accident-related documents: The defendant may seek any photographs, videos, or other physical evidence related to the accident. — Insurance policies and coverage: The defendant may request copies of the plaintiff's insurance policies, including comprehensive and liability coverage. — Expert reports or assessments: The defendant's attorney may ask the plaintiff to provide any expert reports or assessments received regarding the injuries or damages claimed. It is important to note that the specific interrogatories and requests for production in New Mexico may vary depending on the nature of the personal injury case and the strategy of the defendant's attorney.
New Mexico First Interrogatories and Requests for Production to the Plaintiff by the Defendant — Personal Injury are legal documents in a personal injury case filed in New Mexico. These documents are used by the defendant's attorney to gather information and evidence from the plaintiff to build their defense. Below are different types of New Mexico First Interrogatories and Requests for Production to the Plaintiff by the Defendant — Personal Injury: 1. Interrogatories— - General background: The defendant's attorney may request the plaintiff to provide personal information, employment history, medical history, and other relevant background information that could potentially impact the case. — Accident details: The defendant may seek specific information about the circumstances of the accident, including the location, date, time, weather conditions, and any witnesses present. — Injuries and medical treatment: These interrogatories focus on the plaintiff's injuries sustained in the accident, medical treatments received, medical providers consulted, past medical history, and current health conditions. — Financial losses: The defendant's attorney may inquire about the plaintiff's financial losses, including medical expenses, lost wages, property damage, and any other related costs incurred. — Insurance coverage: Interrogatories may ask about the plaintiff's current and past insurance coverage, including health insurance policies, automobile insurance, and any other relevant policies. — Previous legal actions or claims: The defendant may request information about any previous legal actions, lawsuits, or claims the plaintiff has filed or been involved in. — Witness identification: The defendant's attorney may require the plaintiff to identify potential witnesses who might have information or observed the accident. 2. Requests for Production: — Medical records: The defendant may ask the plaintiff to produce all relevant medical records, including hospital records, doctor visits, surgeries, prescriptions, and any other treatment related to the injuries claimed. — Employment records: The defendant's attorney may request the plaintiff's employment records, including pay stubs, tax forms, and other documents related to income and employment history. — Accident-related documents: The defendant may seek any photographs, videos, or other physical evidence related to the accident. — Insurance policies and coverage: The defendant may request copies of the plaintiff's insurance policies, including comprehensive and liability coverage. — Expert reports or assessments: The defendant's attorney may ask the plaintiff to provide any expert reports or assessments received regarding the injuries or damages claimed. It is important to note that the specific interrogatories and requests for production in New Mexico may vary depending on the nature of the personal injury case and the strategy of the defendant's attorney.