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Driving Itinerary

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Posted On 03.07.13 by in Auto Accidents

Most plaintiffs question the need for various discovery questions asked of them.  These questions come in the form of written questions (interrogatories) or questions asked at deposition.  In many cases, these questions have no real relevance to the case, but they are asked by defense lawyers in the hopes that other relevant evidence might be revealed.

One common question we see in interrogatories is this one:

State your itinerary, including the time and place of the beginning of the trip, the time and duration of each stop, and place of destination, and expected time of arrival. 

There are a few good reasons that defense lawyers ask this question (to be fair, we ask the same question of the defendants).

First, the question is looking for each stop made by the driver.  The answer could be relevant because it could include bars or liquor stores (evidence that the driver was drinking).  It could also help us to identify other sources of information that may be necessary to corroborate the evidence, or to disprove the driver’s timetable.

The question also asks for the destination.  This information could help to determine whether the driver was in any sort of hurry—was he going to work (perhaps running late and therefore speeding)?  Was this a place that the driver was familiar with, or could the driver have been using GPS or printed directions, leading to a possible distracted driving scenario.

Putting all of this together, including the expected time of arrival will allow lawyers to put together an automobile accident timeline.  Using commonly available software like MapQuest, we can plug in each stage of the trip to determine how long the trip should take under normal conditions.  Using this information, we can determine if the driver was speeding, or if the driver was running late (evidence that he could have been speeding).

Many of these types of questions are designed to secure the foundation for questions asked in deposition or at trial.  For Maryland district court cases, there are no depositions and limited discovery.  This foundation will help the lawyer anticipate defenses and probe for weaknesses during direct examination.  For circuit court cases, the lawyer will use this information as a skeleton to ask questions of the driver, getting a comprehensive background for the collision.

One final note:  the more information you can give your lawyer, the better.  We usually like to know as much as you can tell us about the twenty-four hour period prior to the auto accident.  This will help us to address defenses and to represent you.

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Contact our automobile accident lawyers at 1-800-776-4529, or online if you have been involve in an accident in Maryland or West Virginia.  We can help you to navigate the world of insurance, and will take your case to court if necessary.

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