When Sarah, a DoorDash courier in Boston, got tangled up in a personal injury lawsuit after an e-bike incident on Beacon Street, the whole thing felt like a blur. Then the opposing counsel’s interrogatories landed. It was like a stack of bricks, demanding answers about everything from her daily routine to the maintenance history of her electric bike. Getting through these legal demands, especially when they’re about a DoorDash e-bike Boston accident, takes a strategic approach that most independent contractors are completely unprepared for.
Key Takeaways
- Your DoorDash work history, vehicle maintenance records, and delivery logs are all evidence. Keep careful records of everything.
- You have to know the difference between being an employee and an independent contractor in Massachusetts, because it completely changes who’s liable and what you have to disclose.
- The moment you get interrogatories, call a lawyer. You need to make sure your responses are accurate, legally compliant, and don’t sink your own case.
- Get ready to answer detailed questions about your e-bike’s specs, when and where you bought it, and any changes you’ve made. They always ask about this.
- If you don’t know an answer, say you don’t recall or the information isn’t available. Never, ever guess.
The Initial Shock: Interrogatories Arrive
Sarah’s e-bike, the same one she’d used for hundreds of deliveries through the Back Bay and North End, was in a collision near the corner of Charles and Cambridge Street. The pedestrian sued her, alleging negligence and asking for a lot of money. A few weeks later, her attorney sent over a thick packet: the plaintiff’s first set of interrogatories. It wasn’t a few questions. This was a dense, multi-dozen-page document demanding information that felt incredibly invasive.
Interrogatories are just written questions from their lawyer to you which you have to answer under oath. They’re a standard part of discovery, the fact-finding phase of a lawsuit, used to collect information and maybe push for a settlement. But for independent contractors like DoorDash couriers, they’re a minefield because the job blurs the lines of responsibility and record-keeping. The questions hit on her training, her usual routes, her work hours, and the specific maintenance she did on her e-bike. They even wanted to know her income from other gig platforms, which felt out of bounds but was fair game in discovery to calculate damages.
Understanding the Scope of Discovery
In Massachusetts, discovery rules fall under the Massachusetts Rules of Civil Procedure, mainly Rule 33. This rule says each side can serve up to 30 written interrogatories (including all the little sub-parts) on the other. But don’t be surprised if a judge allows more if the case is complex. The key is that the information they’re asking for has to be relevant to someone’s claim or defense. It doesn’t even have to be admissible in court, as long as it seems “reasonably calculated to lead to the discovery of admissible evidence.”
I’ve seen it time and again: people who are new to litigation completely underestimate how much information the other side can demand. They think their personal life is off-limits, but in a personal injury case, your entire financial and medical history can become an open book if it’s related to liability or damages. This is why having your documentation in order isn’t just a good idea. It’s a necessity if you’re working as an independent contractor.
Crafting a Strategic Response
Sarah was totally overwhelmed at first, but she sat down with her lawyer to go through every single question. The first ground rule was simple: every answer had to be 100% truthful and precise. Making things up or guessing would only create a bigger mess later, with potential perjury charges on the table.
The “Independent Contractor” Conundrum
A lot of the questions kept circling back to her relationship with DoorDash. Was she an employee? Or an independent contractor? This is a huge deal in injury cases involving gig workers. If a court decided she was an employee, DoorDash could be on the hook for her actions (what lawyers call vicarious liability). But as a contractor, the liability generally stops with Sarah, unless the plaintiff can prove something specific like DoorDash was negligent in how they brought her onto the platform.
Massachusetts law, specifically M.G.L. c. 149, § 148B (the Independent Contractor Law), has a tough three-part test for this. To be a contractor, a worker must: (A) be free from the company’s control and direction in how they do the work; (B) perform work that is outside the company’s usual course of business. And (C) be independently established in that same type of trade or business. Plaintiff’s attorneys will almost always argue that a gig worker fails one of these prongs to try and pull the company into the lawsuit.
For more on this topic, check out our piece on Georgia Gig Workers: 2026 Rights at Stake.
Documenting E-Bike Maintenance and Usage
The interrogatories hammered away on the e-bike itself: purchase date, model, serial number, every maintenance record, and any modifications. Sarah had bought her bike from a shop in Allston two years ago. Luckily, she’d kept the receipt and had a digital log of her regular service appointments at a repair shop on Commonwealth Avenue. That documentation was gold. Without it, she would have been relying on memory, which just doesn’t hold up in court.
For any courier using an e-bike, a careful log is non-negotiable. You need to track the date of purchase, all repairs, any parts you replaced, and even routine stuff like checking tire pressure or brake pads. These are the facts that can shut down a claim that you were negligent with your equipment.
Responding to Specific Interrogatory Types
The questions broke down into a few categories, and we had to approach each one differently:
- Background Information: This was the easy part, name, address, date of birth, education, and job history. All standard.
- Accident Details: They wanted the precise time, date, location, weather, and every action she took before and after the crash, plus names of witnesses and things she said to people. Her 911 call and the police report gave us a solid factual foundation to work from.
- Vehicle Information: Make, model, year, serial number, registration, who owned it, and the full maintenance history. Like I said, her detailed records were a lifesaver here.
- Damages: This covered her own injuries, medical care, lost wages, and any other money she lost. This is where pulling her DoorDash earnings reports became critical.
- Insurance Coverage: They wanted details on all relevant insurance policies, including her personal auto and any commercial coverage. Too many contractors don’t realize they need separate commercial insurance, a mistake that can wipe you out financially.
The Importance of Precision and Avoiding Speculation
One interrogatory asked Sarah to “describe in detail all conversations you had with any DoorDash representative regarding the incident.” She remembered a quick call to DoorDash support right after the accident to report it, but couldn’t recall the exact words. Her attorney told her to state what she remembered, but to also be clear that she couldn’t recall the conversation verbatim. It’s much better to say “I do not recall the exact wording, but I reported the incident and its general nature” than to make up a conversation that can be disproven.
Another question wanted her “average daily earnings” from DoorDash. Instead of giving a rough guess that could be picked apart, Sarah downloaded her actual earnings statements directly from the DoorDash app. This gave us concrete, verifiable data. That kind of factual precision adds credibility to all your answers.
The Role of Legal Counsel
Sarah admits she would have been lost without her attorney. A lawyer’s job isn’t just to translate the legal jargon. It’s to build a strategy for how to frame answers to protect you. For example, some questions are intentionally written to be overly broad or to ask for privileged information. An attorney knows when and how to object, making sure you only provide what the law actually requires.
Think about the traps: a careless answer can sound like an admission of fault, give away damaging information, or create a contradiction that the other lawyer will use against you in a deposition. The attorney goes over every single answer to make sure it’s complete, accurate, and doesn’t contradict other evidence. It’s a painstaking process, and it’s why you have to get a lawyer involved early in any serious lawsuit, especially one involving the gig economy.
A huge part of that is making sure the answers line up with police reports, witness statements, and medical records. Any small inconsistency can be used by the other side to attack your credibility. It’s about presenting a coherent, verifiable story.
What Happens After Responses Are Submitted?
Once Sarah’s interrogatory answers were finalized, signed under oath, and sent off, the discovery process kept moving. Those answers would guide the next steps, like depositions (where she’d be questioned live by the other attorney) or requests for documents. Because her answers were so thorough, she was much better prepared for those next phases, having already pulled together most of the key information.
The plaintiff’s lawyer will use the answers to find weak spots or areas for more questions. They might ask for specific documents mentioned in the responses or schedule depositions with people she identified as witnesses. A solid set of interrogatory answers can actually help you control the story and put you in a stronger position for settlement talks or trial.
Lessons Learned for DoorDash Couriers
Sarah’s situation offers some hard-earned lessons for any DoorDash courier, especially if you’re working in a city like Boston where e-bike accidents are on the rise:
- Document Everything: Keep obsessive records of your earnings, delivery logs, all e-bike maintenance (receipts for parts and service), and any texts or emails with DoorDash. Digital records are your friend.
- Understand Your Status: Get clear on what being an independent contractor means for your liability. DoorDash provides some insurance, but it’s often full of gaps.
- Insurance Matters: Look at your personal insurance policies and seriously consider getting a commercial policy. Your standard auto or homeowner’s insurance probably won’t cover you while you’re working.
- Seek Legal Advice Immediately: If you’re in an accident with an injury, call a lawyer who knows personal injury and gig economy law right away. Don’t wait for the lawsuit to be filed.
- Be Prepared for Scrutiny: Once a lawsuit starts, your work habits, your finances, and your vehicle maintenance are all going under a microscope. Being prepared is the only real defense.
The legal system is messy. For a DoorDash e-bike courier in Boston, a simple incident can blow up into a legal nightmare. In the end, Sarah’s detailed records and her decision to hire a lawyer early put her in a much stronger position to defend herself. Her case is a clear sign that in the gig economy, being prepared and responsible isn’t just a good practice, it’s a survival skill.
Answering interrogatories correctly is a make-or-break moment in a personal injury lawsuit. If you’re a DoorDash courier, knowing the details of your contractor status and having rock-solid documentation of your work can change the entire outcome. Always get professional legal help to get through this, so your rights are protected and your answers are both true and smart. For more on DoorDash injuries and legal cases, check out our analysis.
What are interrogatories in a personal injury lawsuit?
They’re a set of formal, written questions from the other side in a lawsuit that you’re required to answer truthfully and under oath. It’s a key part of the pre-trial “discovery” phase for gathering facts and evidence.
How many interrogatories can be asked in Massachusetts?
Under Massachusetts court rules (Rule 33), a party can typically ask up to 30 questions, including all the sub-parts. A judge can allow more, however, if the case is particularly complex or if both sides agree to it.
Do I need a lawyer to respond to interrogatories?
You’re not legally required to have one, but trying to respond without a lawyer is a very bad idea. An attorney can help you understand the questions, object to improper ones, and make sure your answers don’t accidentally wreck your case.
What kind of documentation should a DoorDash e-bike courier keep?
You should keep everything: e-bike purchase receipts, service logs, and maintenance records. Your delivery history and earnings reports from the app. Your insurance policies. And any important communications you’ve had with DoorDash. This stuff is critical if you get sued.
What happens if I give a false answer in my interrogatory responses?
Lying in interrogatory answers is a huge mistake. Since you’re answering under oath, it can lead to perjury charges, court sanctions, and it will destroy your credibility, tanking your entire case. You must be truthful.