The criteria for retaining an accident reconstruction expert is not whether he has previously testified on behalf of plaintiffs or defendants, but his creden- tials, reliability, and his objective review of the evidence in reaching his final conclusions. Normally it is anticipated that counsel
for the plaintiff or plaintiffs will have complied with Maryland Rule 15-1001 and included all persons who may be entitled to damages by reason of the wrongful death in the complaint as plaintiffs and will follow the format required under Rule 15-1001 in join- ing use plaintiffs as necessary. The discovery propounded to the plaintiffs in the wrongful death action seeks to establish all persons who are classified as primary claimants and those classi- fied as secondary claimants. Discovery is directed to determining all members of the household of the deceased as well as the relationship of the parties.
Discovery is also directed to the basis for claims for pecuniary loss as well as claims for mental anguish, emotional pain and suffering, loss of society, com- panionship, comfort, protection, marital care, parental care, filial care, attention, advise, counsel, training, guidance or education, or other such damages may be applicable based upon the relation- ship of the claimants to the deceased. In addition, discovery is directed to all activities of the deceased plaintiff within eight hours prior to the occurrence. With respect to document production, among the documents requested are the deceased’s birth certificate, the autopsy report and all photographs in possession of plaintiff ’s counsel of the deceased plaintiff or of the vehicles involved in the occurrence. In responding to interrogatories pro-
pounded by plaintiffs, it is my belief that it is better to sit down and meet with the defendant to review each question and
proposed answer in detail rather than sending the interrogatories to the de- fendant with the request that he review and furnish the information to complete the answers to interrogatories. Since the interrogatories are not only directed to the defendant but to his representatives, including the insurance carrier, much of the information will be contained in the investigative file forwarded to me by the insurance carrier. Once the written discovery has been completed, it has been my practice in a wrongful death case to depose all of the plaintiffs and fact witnesses as well as any experts to be called at the time of trial by plaintiffs, including the police officers involved in the investigation of the accident and the accident reconstruction following the occurrence. Since the wrongful death action is a
statutorily created civil remedy under Subtitle 9 of the Annotated Code of Maryland, Courts & Judicial Proceed-
Total Health Family Clinic, Inc.
Ashkan Aazami, D.C. (301) 322-7777
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6521 Annapolis Road Landover Hills, MD 20784 (301) 322-7777
5730-A Silver Hill Road District Heights, MD 20747 (301) 735-5775
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•Spanish speaking Doctor and Staff •Flexible Office Hours
Fall 2008
Trial Reporter
51
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