South Carolina First Interrogatories and Requests for Production to the Plaintiff by the Defendant — Personal Injury cases involve a series of written questions and document requests served by the defendant to the plaintiff as part of the pre-trial discovery process. These interrogatories and requests for production aim to gather pertinent information and evidence related to the personal injury claim. Here are several types of South Carolina First Interrogatories and Requests for Production commonly used in personal injury cases: 1. Interrogatories: — Standard Interrogatories: These are general written questions seeking basic information about the plaintiff, their injuries, and the incident leading to the personal injury claim. — Specific Interrogatories: These interrogatories focus on particular aspects of the case, such as details about medical treatment, prior injuries, witness statements, or insurance coverage. — Expert Witness Interrogatories: These queries target information regarding any experts the plaintiff may be planning to call as witnesses in support of their claim. The defendant can seek qualifications, opinions, and reports from these experts. 2. Requests for Production: — Medical Records Requests: This category encompasses requests for the plaintiff's medical records related to the injuries at the center of the personal injury claim. The defendant can demand copies of medical evaluations, diagnostic test results, treatment plans, and bills. — Employment Records Requests: Defendants may request the plaintiff's employment records to potentially challenge any lost wages or future earning capacity claims made in the lawsuit. — Accident or Incident Report Requests: Defendants commonly request any accident reports, police reports, or incident reports filed regarding the event leading to the personal injury claim. — Photographs or Video Surveillance Requests: Defendants often seek copies of any photographs, videos, or surveillance footage that may exist and pertain to the accident scene, injuries, or the plaintiff's activities post-incident. By utilizing these South Carolina First Interrogatories and Requests for Production, defendants in personal injury cases can gain comprehensive information and evidence necessary for their defense. However, it is important to note that the specific interrogatories and requests for production used may vary depending on the individual circumstances of the case.