DISC 001 Form Interrogatories—General

Transcript

1 DISC-001 (Name, State Bar number, and address): ATTORNEY OR PARTY WITHOUT ATTORNEY TELEPHONE NO.: (Optional): FAX NO. E-MAIL ADDRESS (Optional): (Name): ATTORNEY FOR SUPERIOR COURT OF CALIFORNIA, COUNTY OF SHORT TITLE OF CASE: CASE NUMBER: FORM INTERROGATORIES—GENERAL Asking Party: Answering Party: Set No.: (c) Each answer must be as complete and straightforward Sec. 1. Instructions to All Parties as the information reasonably available to you, including the (a) Interrogatories are written questions prepared by a party rneys or agents, permits. If information possessed by your atto any other party in the action to be to an action that are sent to an interrogatory cannot be answered completely, answer it to answered under oath. The interrogatories below are form the extent possible. interrogatories approved for use in civil cases. (d) If you do not have enough personal knowledge to fully (b) For time limitations, requirements for service on other answer an interrogatory, say so, but make a reasonable and parties, and other details, see Code of Civil Procedure rmation by asking other persons good faith effort to get the info sections 2030.010–2030.410 and t he cases construing those or organizations, unless the information is equally available to sections. the asking party. (c) These form interrogatories do not change existing law (e) Whenever an interrogatory may be answered by relating to interrogatories nor do they affect an answering referring to a document, the document may be attached as an ivilege or make any objection. party’s right to assert any pr exhibit to the response and referred to in the response. If the Sec. 2. Instructions to the Asking Party document has more than one page, refer to the page and (a) These interrogatories are designed for optional use by section where the answer to the interrogatory can be found. ses where the amount demanded parties in unlimited civil ca (f) Whenever an address and telephone number for the exceeds $25,000. Separate interrogatories, Form same person are requested in more than one interrogatory, Interrogatories—Limited Civil Cases (Economic Litigation) you are required to furnish them in answering only the first (form DISC-004), which have no subparts, are designed for interrogatory asking for that information. here the amount demanded is use in limited civil cases w (g) If you are asserting a privilege or making an objection to $25,000 or less; however, those interrogatories may also be ically assert the privilege or an interrogatory, you must specif used in unlimited civil cases. state the objection in your written response. (b) Check the box next to each interrogatory that you want (h) Your answers to these in terrogatories must be verified, the answering party to answer. Use care in choosing those dated, and signed. You may wish to use the following form at interrogatories that are applicable to the case. the end of your answers: INCIDENT in (c) You may insert your own definition of of perjury under the laws of the I declare under penalty tion arises from a course of Section 4, but only where the ac State of California that the foregoing answers are true and curring over a period of time. conduct or a series of events oc correct. (d) The interrogatories in section 16.0, Defendant’s Contentions–Personal Injury, should not be used until the defendant has had a reasonable opportunity to conduct an (DATE) (SIGNATURE) investigation or discovery of plaintiff’s injuries and damages. Sec. 4. Definitions (e) Additional interrogatories may be attached. Words in BOLDFACE CAPITALS in these interrogatories Sec. 3. Instructions to the Answering Party are defined as follows: (a) An answer or other appropriate response must be checked by the asking party. given to each interrogatory (Check one of the following): (a) (b) As a general rule, within 30 days after you are served includes the circumstances and INCIDENT (1) must serve your responses on with these interrogatories, you events surrounding the alleged accident, injury, or the asking party and serve copies of your responses on all other occurrence or breach of contract giving rise to other parties to the action w ho have appeared. See Code of this action or proceeding. Civil Procedure sections 2030.260–2030.270 for details. Page 1 of 8 Form Approved for Optional Use Code of Civil Procedure, FORM INTERROGATORIES—GENERAL Judicial Council of California §§ 2030.010-2030.410, 2033.710 DISC-001 [Rev. January 1, 2008] www.courtinfo.ca.gov

2 DISC-001 1.0 Identity of Persons Answering These Interrogatories means (insert your definition here or (2) INCIDENT on a separate, attached sheet labeled “Sec. ADDRESS, telephone number, and 1.1 State the name, 4(a)(2)”): relationship to you of each PERSON who prepared or of the responses to these assisted in the preparation Do not identify anyone who simply typed or interrogatories. ( reproduced the responses.) — 2.0 General Background Information individual (b) YOU OR ANYONE ACTING ON YOUR BEHALF 2.1 State: employees, your insurance includes you, your agents, your (a) your name; companies, their agents, their em ployees, your attorneys, your (b) every name you have used in the past; and accountants, your investigator s, and anyone else acting on (c) the dates you used each name. your behalf. 2.2 State the date and place of your birth. (c) PERSON includes a natural person, firm, association, iness, trust, limited liability organization, partnership, bus did you have a driver's INCIDENT, 2.3 At the time of the company, corporation, or public entity. license? If so state: (a) the state or ot her issuing entity; (d) DOCUMENT means a writing, as defined in Evidence (b) the license number and type; Code section 250, and includes the original or a copy of (c) the date of issuance; and ting, photostats, photographs, handwriting, typewriting, prin (d) all restrictions. electronically stored informatio n, and every other means of recording upon any tangible thing and form of communicating 2.4 At the time of the INCIDENT, did you have any other pictures, sounds, or or representation, including letters, words, of a motor vehicle? If so, permit or license for the operation symbols, or combinations of them. state: includes any PERSON (e) HEALTH CARE PROVIDER her issuing entity; (a) the state or ot referred to in Code of Civil Procedure section 667.7(e)(3). (b) the license number and type; (c) the date of issuance; and (f) ADDRESS means the street address, including the city, (d) all restrictions. state, and zip code. 2.5 State: Sec. 5. Interrogatories (a) your present residence ADDRESS; The following interrogatories have been approved by the for the past five years; and (b) your residence ADDRESSES Civil Procedure section 2033.710: Judicial Council under Code of ADDRESS. (c) the dates you lived at each CONTENTS 2.6 State: 1.0 Identity of Persons Answering These Interrogatories (a) the name, ADDRESS, and telephone number of your 2.0 General Background Information—Individual present employer or place of self-employment; and 3.0 General Background Info rmation—Business Entity dates of employment, job title, (b) the name, ADDRESS, 4.0 Insurance and nature of work for each employer or 5.0 [Reserved] self-employment you have had from five years before or Emotional Injuries 6.0 Physical, Mental, the INCIDENT until today. 7.0 Property Damage 8.0 Loss of Income or Earning Capacity 2.7 State: 9.0 Other Damages (a) the name and ADDRESS of each school or other 10.0 Medical History academic or vocational institution you have attended, 11.0 Other Claims and Previous Claims beginning with high school; 12.0 Investigation—General (b) the dates you attended; 13.0 Investigation—Surveillance (c) the highest grade level you have completed; and 14.0 Statutory or R egulatory Violations (d) the degrees received. 15.0 Denials and Special or Affirmative Defenses 16.0 Defendant’s Contentions Personal Injury 2.8 Have you ever been convicted of a felony? If so, for 17.0 Responses to Request for Admissions each conviction state: 18.0 [Reserved] (a) the city and state w here you were convicted; [Reserved] 19.0 (b) the date of conviction; 20.0 How the Incident Occurred—Motor Vehicle (c) the offense; and 25.0 [Reserved] (d) the court and case number. 30.0 [Reserved] 40.0 [Reserved] 2.9 Can you speak English with ease? If not, what 50.0 Contract language and dialect do you normally use? [Reserved] 60.0 70.0 Unlawful Detainer [See separate form DISC-003] 2.10 Can you read and write Engl ish with ease? If not, what [See separate form DISC-004] 101.0 Economic Litigation language and dialect do you normally use? form DISC-002] [See separate 200.0 Employment Law [See separate form FL-145] Family Law DISC-001 [Rev. January 1, 2008] Page 2 of 8 FORM INTERROGATORIES—GENERAL

3 DISC-001 3.4 Are you a joint venture? If so, state: INCIDENT were you acting as an 2.11 At the time of the (a) the current joint venture name; PERSON? If so, state: agent or employee for any (b) all other names used by the joint venture during the and telephone number of that (a) the name, ADDRESS, past 10 years and the dates each was used; and PERSON: ADDRESS of each joint venturer; and (c) the name and (b) a description of your duties. of the principal place of business. ADDRESS (d) the 2.12 At the time of the INCIDENT did you or any other corporated association? 3.5 Are you an unin person have any physical, emotional, or mental disability or If so, state: condition that may have contribut ed to the occurrence of the (a) the current unincorporated association name; INCIDENT? If so, for each person state: (b) all other names used by the unincorporated association ADDRESS, and telephone number; (a) the name, during the past 10 years and t he dates each was used; (b) the nature of the disability or condition; and and (c) the manner in which the disability or condition (c) the ADDRESS of the principal place of business. INCIDENT. contributed to the occurrence of the INCIDENT 2.13 Within 24 hours before the did you or any 3.6 Have you done business under a fictitious name during the past 10 years? If so, fo r each fictitious name state: use or take any of the person involved in the INCIDENT following substances: alcoholic beverage, marijuana, or (a) the name; (b) the dates each was used; other drug or medication of any kind (prescription or not)? If (c) the state and county of each fictitious name filing; and so, for each person state: (d) the ADDRESS of the principal place of business. and telephone number; ADDRESS, (a) the name, (b) the nature or descr iption of each substance; (c) the quantity of each substance used or taken; any public entity regis- 3.7 Within the past five years has (d) the date and time of day when each substance was used tered or licensed your business? If so, for each license or or taken; registration: ADDRESS where each substance was used or (e) the (a) identify the license or registration; taken; (b) state the name of the public entity; and (f) the name, ADDRESS, and telephone number of each (c) state the dates of issuance and expiration. person who was present when each substance was used or taken; and 4.0 Insurance ADDRESS, (g) the name, and telephone number of any HEALTH CARE PROVIDER who prescribed or furnished INCIDENT, was there in effect any 4.1 At the time of the tion for which it was the substance and the condi policy of insurance through which you were or might be prescribed or furnished. insured in any manner (for example, primary, pro-rata, or excess liability coverage or medical expense coverage) for 3.0 General Background Information — Business Entity the damages, claims, or actions th at have arisen out of the INCIDENT? If so, for each policy state: 3.1 Are you a corporation? If so, state: (a) the name stated in the current articles of incorporation; (a) the kind of coverage; (b) the name and ADDRESS of the insurance company; (b) all other names used by the corporation during the past 10 years and the dates each was used; and telephone number of each (c) the name, ADDRESS, (c) the date and place of incorporation; named insured; (d) the policy number; (d) the of the principal place of business; and ADDRESS (e) the limits of coverage for each type of coverage con- (e) whether you are qualified to do business in California. tained in the policy; (f) whether any reservation of rights or controversy or e: 3.2 Are you a partnership? If so, stat (a) the current partnership name; coverage dispute exists between you and the insurance company; and (b) all other names used by th e partnership during the past 10 years and the dates each was used; ADDRESS, (g) the name, and telephone number of the tnership and, if so, under (c) whether you are a limited par custodian of the policy. the laws of what jurisdiction; 4.2 Are you self-insured under any statute for the damages, (d) the name and ADDRESS of each general partner; and INCIDENT? claims, or actions that If have arisen out of the ADDRESS (e) the of the principal place of business. so, specify the statute. ility company? If so, state: 3.3 Are you a limited liab [Reserved] 5.0 current articles of organization; (a) the name stated in the (b) all other names used by the company during the past 10 6.0 Physical, Mental, or Emotional Injuries years and the date each was used; of the articles of organization; (c) the date and place of filing cal, mental, or emotional 6.1 Do you attribute any physi (d) the ADDRESS of the principal place of business; and injuries to the INCIDENT? (If your answer is “no,” do not (e) whether you are qualified to do business in California. answer interrogatories 6.2 through 6.7). 6.2 Identify each injury and INCIDENT you attribute to the the area of your body affected. DISC-001 [Rev. January 1, 2008] Page 3 of 8 FORM INTERROGATORIES—GENERAL

4 DISC-001 (c) state the amount of damage you are claiming for each laints that you attribute to 6.3 Do you still have any comp If so, for each complaint state: item of pr operty and how the amount was calculated; and the INCIDENT? ADDRESS, and s sold, state the name, (d) if the property wa (a) a description; (b) whether the complaint is subsiding, remaining the sa me, telephone number of the seller, the date of sale, and the or becoming worse; and sale price. (c) the frequency and duration. 6.4 Did you receive any consultation or examination 7.2 Has a written estimate or evaluation been made for any (except from expert witnesses covered by Code of Civil item of property referred to in your answer to the preceding Procedure sections 2034.210–2034. 310) or treatment from a interrogatory? If so, for each estimate or evaluation state: u attribute to for any injury yo HEALTH CARE PROVIDER and telephone number of the (a) the name, ADDRESS, the HEALTH CARE PROVIDER INCIDENT? If so, for each PERSON who prepared it and the date prepared; state: and telephone number of each ADDRESS, (b) the name, and telephone number; (a) the name, ADDRESS, who has a copy of it; and PERSON examination, or treatment (b) the type of consultation, (c) the amount of damage stated. provided; consultation, examination, or (c) the dates you received 7.3 Has any item of property referred to in your answer to treatment; and so, for each item state: interrogatory 7.1 been repaired? If (d) the charges to date. (a) the date repaired; (b) a description of the repair; 6.5 Have you taken any medication, prescribed or not, as a (c) the repair cost; result of injuries that you attribute to the INCIDENT? If so, ADDRESS, and telephone number of the (d) the name, for each medication state: PERSON who repaired it; (a) the name; ADDRESS, and telephone number of the (e) the name, PERSON (b) the who prescribed or furnished it; who paid for the repair. PERSON (c) the date it was prescribed or furnished; (d) the dates you began and stopped taking it; and 8.0 Loss of Income or Earning Capacity (e) the cost to date. of income or earning capacity 8.1 Do you attribute any loss INCIDENT to the (If your answer is “no,” do not answer ? 6.6 Are there any other medi cal services ne cessitated by interrogatories 8.2 through 8.8). u attribute to the INCIDENT the injuries that yo that were not previously listed (for example, ambulance, nursing, r each service state: prosthetics)? If so, fo 8.2 State: (a) the nature; (a) the nature of your work; (b) the date; and at the time of the (b) your job title INCIDENT; (c) the cost; and (c) the date your employment began. and telephone number (d) the name, ADDRESS, date before the that you 8.3 State the last INCIDENT of each provider. worked for compensation. 6.7 Has any advised that you HEALTH CARE PROVIDER may require future or additional treatment for any injuries 8.4 State your monthly in INCIDENT come at the time of the that you attribute to the INCIDENT? If so, for each injury and how the amount was calculated. state: HEALTH CARE of each ADDRESS (a) the name and 8.5 State the date you returned to work at each place of PROVIDER; employment following the INCIDENT. was advised; and h the treatment (b) the complaints for whic (c) the nature, duration, and estimated cost of the work and for which you lost 8.6 State the dates you did not treatment. INCIDENT. income as a result of the 7.0 Property Damage 8.7 State the total income you have lost to date as a result and how the amount was calculated. INCIDENT of the 7.1 Do you attribute any loss of or damage to a vehicle or INCIDENT ? If so, for each item of other property to the property: 8.8 Will you lose income in the future as a result of the (a) describe the property; INCIDENT? If so, state: (a) the facts upon which you base this contention; (b) describe the nature and location of the damage to the (b) an estimate of the amount; property; (c) an estimate of how long you will be unable to work; and (d) how the claim for future income is calculated. DISC-001 [Rev. January 1, 2008] Page 4 of 8 FORM INTERROGATORIES—GENERAL

5 DISC-001 9.0 Other Damages (c) the court, names of the parties, and case number of any action filed; 9.1 Are there any other damages that you attribute to the (d) the name, ADDRESS, and telephone number of any INCIDENT? If so, for each item of damage state: attorney representing you; (a) the nature; (e) whether the claim or action has been resolved or is (b) the date it occurred; pending; and (c) the amount; and (f) a description of the injury. ADDRESS, (d) the name, and telephone number of each to whom an obligation was incurred. PERSON e you made a written claim or 11.2 In the past 10 years hav demand for workers' compensation benefits? If so, for each claim or demand state: support the existence or amount DOCUMENTS 9.2 Do any of any item of damages claimed in interrogatory 9.1? If so, giving rise to INCIDENT (a) the date, time, and place of the the claim; ADDRESS, describe each document and state the name, and telephone number of the PERSON who has each (b) the name, ADDRESS, and telephone number of your DOCUMENT. employer at the time of the injury; ADDRESS, (c) the name, and telephone number of the workers’ compensation insurer and the claim number; 10.0 Medical History (d) the period of time during which you received workers’ compensation benefits; did you have com- 10.1 At any time before the INCIDENT ed the same part of your body plaints or injuries that involv (e) a description of the injury; INCIDENT? claimed to have been injured in the If so, for ADDRESS, (f) the name, and telephone number of any each state: HEALTH CARE PROVIDER who provided services; and he Workers’ Compensation Appeals (g) the case number at t (a) a description of the complaint or injury; Board. (b) the dates it began and ended; and ADDRESS, (c) the name, and telephone number of each 12.0 Investigation—General whom you consulted or HEALTH CARE PROVIDER who examined or treated you. ADDRESS, and telephone number of 12.1 State the name, each individual: 10.2 List all physical, mental , and emotional disabilities you (a) who witnessed the INCIDENT or the events occurring INCIDENT. had immediately before the (You may omit INCIDENT; immediately before or after the mental or emotional disabilities unless you attribute any INCIDENT; scene of the ent at the (b) who made any statem ) mental or emotional injury to the INCIDENT. atements made about the (c) who heard any st INCIDENT by any individual at the scene; and did you sustain 10.3 At any time after the INCIDENT, YOU OR ANYONE ACTING ON YOUR BEHALF (d) who injuries of the kind for which you are now claiming (except for INCIDENT claim has knowledge of the damages? If so, for each incident giving rise to an injury expert witnesses covered by Code of Civil Procedure state: section 2034). (a) the date and the place it occurred; (b) the name, ADDRESS, and telephone number of any 12.2 Have YOU OR ANYONE ACTING ON YOUR other involved; PERSON BEHALF interviewed any individual concerning the (c) the nature of any injuries you sustained; INCIDENT? If so, for each individual state: (d) the name, ADDRESS, and telephone number of each (a) the name, ADDRESS, and telephone number of the who you consulted or who HEALTH CARE PROVIDER individual interviewed; examined or treated you; and (b) the date of the interview; and (e) the nature of the treatment and its duration. and telephone number of the (c) the name, ADDRESS, PERSON who conducted the interview. 11.0 Other Claims and Previous Claims 11.1 Except for this action, in the past 10 years have you 12.3 Have YOU OR ANYONE ACTING ON YOUR filed an action or made a written claim or demand for obtained a written or recorded statement from any BEHALF compensation for your personal injuries? If so, for each INCIDENT? individual concerning the If so, for each action, claim, or demand state: statement state: (a) the date, time, and plac e and location (closest street (a) the name, ADDRESS, and telephone number of the giving rise or intersection) of the ADDRESS INCIDENT individual from w hom the statement was obtained; to the action, claim, or demand; and telephone number of the ADDRESS, (b) the name, (b) the name, ADDRESS, and telephone number of each individual who obtained the statement; PERSON against whom the claim or demand was made (c) the date the statement was obtained; and or the action filed; (d) the name, ADDRESS, and telephone number of each who has the original statement or a copy. PERSON DISC-001 [Rev. January 1, 2008] Page 5 of 8 FORM INTERROGATORIES—GENERAL

6 DISC-001 13.2 Has a written report been prepared on the YOU OR ANYONE ACTING ON YOUR BEHALF 12.4 Do or videotapes depicting any know of any photographs, films, h written report state: surveillance? If so, for eac place, object, or individual concerning the INCIDENT or (a) the title; plaintiff's injuries? If so, state: (b) the date; and telephone number of the (c) the name, ADDRESS, (a) the number of photographs or feet of film or videotape; individual who prepared the report; and (b) the places, objects, or per sons photographed, filmed, or and telephone number of each (d) the name, ADDRESS, videotaped; PERSON who has the original or a copy. (c) the date the photographs, films, or videotapes were taken; gulatory Violations 14.0 Statutory or Re and telephone number of the ADDRESS, (d) the name, 14.1 Do YOU OR ANYONE ACTING ON YOUR BEHALF individual taking the photographs, films, or videotapes; PERSON contend that any INCIDENT involved in the and e, or regulation and that the violated any statute, ordinanc (e) the name, ADDRESS, and telephone number of each INCIDENT? If violation was a legal (proximate) cause of the who has the original or a copy of the PERSON so, identify the name, ADDRESS, and telephone number of photographs, films, or videotapes. and the statute, ordinanc PERSON e, or regulation that each was violated. YOU OR ANYONE ACTING ON YOUR BEHALF 12.5 Do know of any diagram, reproduction, or model of any place or 14.2 Was any PERSON cited or charged with a violation of thing (except for items developed by expert witnesses any statute, ordinance, or regulation as a result of this covered by Code of Civil Procedure sections 2034.210– PERSON If so, for each INCIDENT? state: If so, for each item INCIDENT? 2034.310) concerning the (a) the name, and telephone number of the ADDRESS, state: PERSON; (a) the type (i.e., diagram , reproduction, or model); (b) the statute, ordinance, or regulation allegedly violated; (b) the subject matter; and (c) whether the entered a plea in response to the PERSON (c) the name, and telephone number of each ADDRESS, so, the plea entered; and citation or charge and, if PERSON who has it. (d) the name and ADDRESS of the court or administrative 12.6 Was a report made by any PERSON concerning the agency, names of the parties, and case number. If so, state: INCIDENT? 15.0 Denials and Special or Affirmative Defenses (a) the name, title, identification number, and employer of 15.1 Identify each denial of a material allegation and each who made the report; the PERSON special or affirmative defense in your pleadings and for (b) the date and type of report made; each: and telephone number of the ADDRESS, (c) the name, u base the denial or special (a) state all facts upon which yo PERSON for whom the report was made; and or affirmative defense; ADDRESS, and telephone number of each (d) the name, ADDRESSES, (b) state the names, and telephone numbers PERSON who has the original or a copy of the report. of all PERSONS who have knowledge of those facts; and YOU OR ANYONE ACTING ON YOUR 12.7 Have (c) identify all DOCUMENTS and other tangible things that BEHALF inspected the scene of the INCIDENT? If so, for support your denial or specia l or affirmative defense, and each inspection state: ADDRESS, state the name, and telephone number of (a) the name, and telephone number of the ADDRESS, PERSON DOCUMENT. the who has each individual making the inspection (except for expert 16.0 Defendant’s Contentions—Personal Injury witnesses covered by Code of Civil Procedure other than you or PERSON, 16.1 Do you contend that any sections 2034.210–2034.310); and plaintiff, contributed to the occurrence of the INCIDENT or (b) the date of the inspection. the injuries or damages claimed by plaintiff? If so, for each PERSON: 13.0 Investigation—Surveillance and telephone number of (a) state the name, ADDRESS, 13.1 Have YOU OR ANYONE ACTING ON YOUR BEHALF the PERSON; individual involved in the conducted surveillance of any (b) state all facts upon which you base your contention; or any party to this action? If so, for each sur- INCIDENT ADDRESSES, (c) state the names, and telephone numbers veillance state: who have knowledge of the facts; and PERSONS of all and telephone number of the (a) the name, ADDRESS, and other tangible things that DOCUMENTS (d) identify all individual or party; ADDRESS, support your contenti on and state the name, (b) the time, date, and place of the surveillance; who has each and telephone number of the PERSON (c) the name, ADDRESS, and telephone number of the or thing. DOCUMENT individual who conducted the surveillance; and plaintiff was not injured in the 16.2 Do you contend that and telephone number of each (d) the name, ADDRESS, INCIDENT? If so: who has the original or a copy of any PERSON (a) state all facts upon which you base your contention; surveillance photograph, film, or videotape. (b) state the names, ADDRESSES, and telephone numbers of all who have knowledge of the facts; and PERSONS DOCUMENTS (c) identify all and other tangible things that on and state the name, support your contenti ADDRESS, who has each and telephone number of the PERSON or thing. DOCUMENT DISC-001 [Rev. January 1, 2008] Page 6 of 8 FORM INTERROGATORIES—GENERAL

7 DISC-001 16.8 Do you contend that any of the costs of repairing the 16.3 Do you contend that the injuries or the extent of the property damage claimed by plaintiff in discovery injuries claimed by plaintiff as disclosed in discovery proceedings thus far in this case were unreasonable? If so: proceedings thus far in this case were not caused by the If so, for each injury: ? INCIDENT (a) identify each cost item; (a) identify it; (b) state all facts upon which you base your contention; (b) state all facts upon which you base your contention; and telephone numbers (c) state the names, ADDRESSES, ADDRESSES, (c) state the names, and telephone numbers who have knowledge of the facts; and PERSONS of all who have knowledge of the facts; and of all PERSONS and other tangible things that DOCUMENTS (d) identify all DOCUMENTS and other tangible things that (d) identify all support your contenti ADDRESS, on and state the name, ADDRESS, support your contention and state the name, and telephone number of the PERSON who has each who has each PERSON and telephone number of the DOCUMENT or thing. or thing. DOCUMENT YOU OR ANYONE ACTING ON YOUR BEHALF 16.9 Do 16.4 Do you contend t hat any of the services furnished by have any (for example, insurance bureau DOCUMENT HEALTH CARE PROVIDER any claimed by plaintiff in index reports) concerning claims for personal injuries made discovery proceedings thus far in this case were not due to by a plaintiff in this case? If INCIDENT before or after the the ? INCIDENT If so: so, for each plaintiff state: (a) identify each service; DOCUMENT; (a) the source of each (b) state all facts upon which you base your contention; (b) the date each claim arose; and telephone numbers ADDRESSES, (c) state the names, (c) the nature of each claim; and who have knowledge of the facts; and of all PERSONS (d) the name, and telephone number of the ADDRESS, (d) identify all and other tangible things that DOCUMENTS PERSON who has each DOCUMENT. support your contenti ADDRESS, on and state the name, PERSON who has each and telephone number of the 16.10 Do YOU OR ANYONE ACTING ON YOUR BEHALF DOCUMENT or thing. DOCUMENT have any concerning the pas t or present physical, mental, or emotional condition of any plaintiff in that any of the costs of services 16.5 Do you contend this case from a not previously HEALTH CARE PROVIDER claimed as HEALTH CARE PROVIDER furnished by any witnesses covered by Code of identified (except for expert damages by plaintiff in discovery proceedings thus far in 2034.210–2034.310)? If so, for Civil Procedure sections this case were not necessary or unreasonable? If so: each plaintiff state: (a) identify each cost; ADDRESS, and telephone number of each (a) the name, (b) state all facts upon which you base your contention; HEALTH CARE PROVIDER; ADDRESSES, and telephone numbers (c) state the names, (b) a description of each DOCUMENT ; and who have knowledge of the facts; and of all PERSONS (c) the name, ADDRESS, and telephone number of the and other tangible things that (d) identify all DOCUMENTS DOCUMENT. who has each PERSON ADDRESS, support your contention and state the name, and telephone number of the PERSON who has each 17.0 Responses to Request for Admissions DOCUMENT or thing. h request for admission served 17.1 Is your response to eac 16.6 Do you contend that any part of the loss of earnings or unqualified admission? If not, with these interrogatories an income claimed by plaintiff in discovery proceedings thus far for each response that is not an unqualified admission: in this case was unreasonable or was not caused by the (a) state the number of the request; ? INCIDENT If so: (b) state all facts upon which you base your response; (a) identify each part of the loss; and telephone numbers ADDRESSES, (c) state the names, (b) state all facts upon which you base your contention; PERSONS who have knowledge of those facts; of all ADDRESSES, and telephone numbers (c) state the names, and who have knowledge of the facts; and of all PERSONS DOCUMENTS and other tangible things that (d) identify all and other tangible things that DOCUMENTS (d) identify all support your response and state the name, ADDRESS, ADDRESS, support your contention and state the name, who has each PERSON and telephone number of the and telephone number of the PERSON who has each or thing. DOCUMENT DOCUMENT or thing. 18.0 [Reserved] any of the property damage 16.7 Do you contend that [Reserved] 19.0 Proceedings thus far in this claimed by plaintiff in discovery case was not caused by the INCIDENT If so: ? curred—Motor Vehicle 20.0 How the Incident Oc (a) identify each item of property damage; 20.1 State the date, time, and place of the INCIDENT (b) state all facts upon which you base your contention; ADDRESS (closest street or intersection). ADDRESSES, and telephone numbers (c) state the names, who have knowledge of the facts; and PERSONS of all 20.2 For each vehicle involved in the INCIDENT, state: (d) identify all and other tangible things that DOCUMENTS support your contention and state the name, ADDRESS, (a) the year, make, model, and license number; who has each and telephone number of the PERSON (b) the name, ADDRESS, and telephone number of the DOCUMENT or thing. driver; DISC-001 [Rev. January 1, 2008] Page 7 of 8 FORM INTERROGATORIES—GENERAL

8 DISC-001 and telephone number of each ADDRESS, (c) the name, (d) state the name, and telephone number of ADDRESS, occupant other t han the driver; who has custody of each defective part. each PERSON and telephone number of each (d) the name, ADDRESS, registered owner; and telephone number of ADDRESS, 20.11 State the name, (e) the name, ADDRESS, and telephone number of each who has had possession each owner and each PERSON lessee; INCIDENT of each vehicle involved in the since the INCIDENT. (f) the name, ADDRESS, and telephone number of each owner other than the registered owner or lien holder; and 25.0 [Reserved] (g) the name of each owner who gave permission or [Reserved] 30.0 consent to the driver to operate the vehicle. [Reserved] 40.0 20.3 State the and location where your trip ADDRESS began and the and location of your destination. ADDRESS 50.0 Contract 50.1 For each agreement alleged in the pleadings: you followed from the 20.4 Describe the route that INCIDENT, and beginning of your trip to the location of the that is part of the agreement (a) identify each DOCUMENT other than routine traffic state the location of each stop, and telephone ADDRESS, and for each state the name, stops, during the trip leading up to the INCIDENT. number of each PERSON who has the DOCUMENT; agreement not in writing, the (b) state each part of the 20.5 State the name of the street or roadway, the lane of and telephone number of each ADDRESS, name, el of each vehicle involved in travel, and the direction of trav PERSON agreeing to that provisi on, and the date that for the 500 feet of travel before the INCIDENT the part of the agreement was made; INCIDENT. (c) identify all that evidence any part of the DOCUMENTS agreement not in writing and for each state the name, INCIDENT occur at an intersection? If so, 20.6 Did the ADDRESS, and telephone number of each PERSON describe all traffic control device s, signals, or signs at the who has the DOCUMENT; intersection. (d) identify all DOCUMENTS that are part of any modification to the agreement, and for each state the 20.7 Was there a traffic signal facing you at the time of the ADDRESS, and telephone number of each name, INCIDENT? If so, state: who has the DOCUMENT; PERSON (a) your location wh en you first saw it; (e) state each modification not in writing, the date, and the (b) the color; ADDRESS, and telephone number of each name, (c) the number of seconds it had been that color; and PERSON agreeing to the modificati on, and the date the (d) whether the color changed between the time you first modification was made; saw it and the INCIDENT. that evidence any modification DOCUMENTS (f) identify all of the agreement not in writing and for each state the name, ADDRESS, and telephone number of each 20.8 State how the INCIDENT occurred, giving the speed, who has the PERSON DOCUMENT. direction, and location of each vehicle involved: INCIDENT; (a) just before the 50.2 Was there a breach of any agreement alleged in the INCIDENT; and (c) just (b) at the time of the pleadings? If so, for each breach describe and give the date INCIDENT. after the you claim is the breach of the of every act or omission that agreement. a malfunction or defect in 20.9 Do you have information that 50.3 Was performance of any agreement alleged in the a vehicle caused the INCIDENT ? If so: pleadings excused? If so, i dentify each agreement excused (a) identify the vehicle; and state why performance was excused. unction or defect; (b) identify each malf and telephone number of (c) state the name, ADDRESS, 50.4 Was any agreement alleged in the pleadings terminated PERSON each who is a witness to or has information by mutual agreement, release, accord and satisfaction, or n or defect; and about each malfunctio novation? If so, identify eac h agreement terminated, the date ADDRESS, and telephone number of (d) state the name, sis of the termination. of termination, and the ba each PERSON who has custody of each defective part. 50.5 Is any agreement alleged in the pleadings unenforce- 20.10 Do you have information that any malfunction or able? If so, identify each u nenforceable agreement and the injuries sustained in the defect in a vehicle contributed to state why it is unenforceable. INCIDENT? If so: (a) identify the vehicle; 50.6 Is any agreement alleged in the pleadings ambiguous? If so, identify each ambiguous agreement and state why it is unction or defect; (b) identify each malf ambiguous. ADDRESS, and telephone number of (c) state the name, who is a witness to or has information each PERSON 60.0 [Reserved] about each malfunctio n or defect; and DISC-001 [Rev. January 1, 2008] Page 8 of 8 FORM INTERROGATORIES—GENERAL

Related documents