Free Interrogatories Propounded - District Court of Delaware - Delaware

Case 1:08-cv—00001-G|\/IS Document 12 Filed 03/10/2008 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
DISTRICT OF DELAWARE
KENNETH S. BANNING, I R.,
PLAINTIFF, C.A. NO. 08-00001 GMS
v. TRIAL BY JURY DEMANDED
ALIN AUGUSTIN l\/IASCA AND
MAHAI DORU POP,
DEFENDANTS.
PLAINTIEITS INTERROGATORIES DIRECTED TO
DEPENDANT ALIN AUGUSTIN MASCA
AND NOW, comes the Plaintiff above named who does request Defendants answer the
following Interrogatories under oath within (3 0) days . These interrogatories shall be deemed
continuing so as to require further or additional answers up to the time of trial if additional and
subsequent information is obtained by the Defendant(s).
1. Provide the state in which your current driver’s license was issued, set forth your
driver’s license number, the date the license was issued as well as a description of any
restrictions on said license.
ANSWER:
2. Identify every other state in which you currently possess or have possessed a driver’s
license over the past twenty (20) year time frame and for each set forth your driver’s license
number, the date said license was issued as well as a description of any restrictions on said
licenses.
ANSWER:
3. State whether or not your driver’s license has ever been suspended or revoked in any

Case 1 :08-cv-00001-GIVIS Document 12 Filed 03/10/2008 Page 2 of 4
state and if so, set forth the reason why it was suspended or revoked, state in which it was
suspended or revoked, the date and length of the suspension and the date your license was
reinstated.
ANSWER:
4. In your own words, describe how the accident, as averred in plaintiff s Complaint
took place
ANSWER:
5. State what part of your vehicle came into contact with the plaintiff.
ANSWER:
6. lf you had not been involved in the accident which is the subject of this litigation,
state where you were planning on going or in other words your next intended destination.
ANSWER:
7. During the ten year time period prior to the accident which is the subject of this
litigation, have you ever been involved in any other accidents?
ANSWER:
8. If your response to the above is in the aftirmative, provide a description of the
accident providing the date and location of same as well as any citation that you may have
received as a result of same, the name of any individuals involved in each said incident and
whether or not any individuals including yourself made any claims for injury and/or damages as
a result of said accident.
ANSWER:

Case 1 :08-cv-00001-GIVIS Document 12 Filed 03/10/2008 Page 3 of 4
9. During the ten year period prior to the accident which is subject to this litigation, have
you ever been cited for any moving violation?
ANSWER:
l0. lf you responded affirmatively to the immediately preceding interrogatory, set forth
the nature of the violation/citation, the date and time of same, the state wherein said violation or
citation took place and whether or not you have ever been declared a habitual offender related to
any moving violations or citations in any state or jurisdiction.
ANSWER:
l l. At the time of the accident which is the subject of this litigation, state the identify of
the owner of the vehicle to which you were operating that was involved in this collision and
whether or not said vehicle was being provided by any sort of trip lease or other leasehold
arrangement?
ANSWER:
12. Was the vehicle that you were operating at the time of the incident set forth in the
Complaint repaired by any body shop or other collision repair specialist and if so set forth the
name, address and phone number for the entity or person that made the repairs, describe the
nature and extent of said repairs.
ANSWER:
13. Did you consume any alcoholic beverages during the 24 hour period of time before
the accident which is the subject of this litigation and if so, describe the nature and amount of
same.
ANSWER:
l4. Did you consume or take any over the counter medication or prescription medication

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during the 24 hour period of time before the accident which is the subject of this litigation and if
so, set forth the name and amount of the medication and the time of day when said medication
was ingested.
ANSWER;
15. Do you say or do know anybody else who will say that the plaintiff performed or
omitted to perform any act which caused or contributed to the casualty herein complained of and
if so, set forth each such act and/or such failure to act and identify by name, address and phone
number each person with knowledge relative to said act or omission.
ANSWER:
ROl3lNSON GRAYSON DRYDEN
& wmgn
`i°"*:,g~·* r*~"\\

STE` H y rl?. DRYDEN, ESQUIRE
Bar l.D, No. 2157
910 Foulk Road, Suite 200
Wilmington, DE 19803
(302) 655-6262
Attorney for Plaintiff
Dated; 3 r lt>~ ¤i>gj"

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