DISC-001
ATTORNEY OR PARTY WITHOUT ATTORNEY
(Name, State Bar number, and address):
FAX NO.
(Optional):
E-MAIL ADDRESS
(Optional):
ATTORNEY FOR
(Name):
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
as the information reasonably available to you, including the
information possessed by your atto
rneys or agents, permits. If
an interrogatory cannot be answered completely, answer it to
the extent possible.
Sec. 1. Instructions to All Parties
(a) Interrogatories are written questions prepared by a party
to an action that are sent to
any other party in the action to be
answered under oath. The interrogatories below are form
interrogatories approved for use in civil cases.
(b) For time limitations, requirements for service on other
parties, and other details, see Code of Civil Procedure
sections 2030.010–2030.410 and t
he cases construing those
sections.
(d) If you do not have enough personal knowledge to fully
answer an interrogatory, say so, but make a reasonable and
good faith effort to get the info
rmation by asking other persons
or organizations, unless the information is equally available to
the asking party.
(c) These form interrogatories do not change existing law
relating to interrogatories nor do they affect an answering
party’s right to assert any pr
ivilege or make any objection.
(e) Whenever an interrogatory may be answered by
referring to a document, the document may be attached as an
exhibit to the response and referred to in the response. If the
document has more than one page, refer to the page and
section where the answer to
the interrogatory can be found.
Sec. 2. Instructions to the Asking Party
(a) These interrogatories are designed for optional use by
parties in unlimited civil ca
ses where the amount demanded
exceeds $25,000. Separate interrogatories, Form
Interrogatories—Limited Civil Cases (Economic Litigation)
(form DISC-004), which have no subparts, are designed for
use in limited civil cases w
here the amount demanded is
$25,000 or less; however, those interrogatories may also be
used in unlimited civil cases.
(f) Whenever an address and telephone number for the
same person are requested in more than one interrogatory,
you are required to furnish them in answering only the first
interrogatory asking for that information.
(g) If you are asserting a privilege or making an objection to
an interrogatory, you must specif
ically assert the privilege or
state the objection in your written response.
(b) Check the box next to each interrogatory that you want
the answering party to answer. Use care in choosing those
interrogatories that are applicable to the case.
(h) Your answers to these in
terrogatories must be verified,
dated, and signed. You may wish to use the following form at
the end of your answers:
(c) You may insert your own definition of
INCIDENT
in
Section 4, but only where the ac
tion arises from a course of
conduct or a series of events oc
curring over a period of time.
I declare under penalty
of perjury under the laws of the
State of California that the
foregoing answers are true and
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
investigation or discovery of plaintiff’s injuries and damages.
(DATE) (SIGNATURE)
(e) Additional interrogatories may be attached.
Sec. 4. Definitions
Sec. 3. Instructions to the Answering Party
Words in
BOLDFACE CAPITALS
in these interrogatories
(a) An answer or other appropriate response must be
given to each interrogatory
checked by the asking party.
are defined as follows:
(a)
(Check one of the following):
(b) As a general rule, within 30 days after you are served
with these interrogatories, you
must serve your responses on
the asking party and serve copies of your responses on all
other parties to the action w
ho have appeared. See Code of
Civil Procedure sections 2030.260–2030.270 for details.
(1)
INCIDENT
includes the circumstances and
events surrounding the alleged accident, injury, or
other occurrence or breach of
contract giving rise to
this action or proceeding.
Page 1 of 8
Code of Civil Procedure,
§§ 2030.010-2030.410, 2033.710
Form Approved for Optional Use
Judicial Council of California
DISC-001 [Rev. January 1, 2008]
FORM INTERROGATORIES—GENERAL
TELEPHONE NO.:
1.0 Identity of Persons Answering These Interrogatories (2) INCIDENT means (insert your definition here or
on a separate, attached sheet labeled “Sec.
4(a)(2)”):
1.1 State the name, ADDRESS, telephone number, and
relationship to you of each PERSON who prepared or
assisted in the preparation of the responses to these
interrogatories. (Do not identify anyone who simply typed or
reproduced the responses.)
2.0 General Background Information—individual
(b) YOU OR ANYONE ACTING ON YOUR BEHALF
includes you, your agents, your employees, your insurance
companies, their agents, their employees, your attorneys, your
accountants, your investigators, and anyone else acting on
your behalf.
2.1 State:
(a) your name;
(b) every name you have used in the past; and
(c) the dates you used each name.
2.2 State the date and place of your birth.
(c) PERSON includes a natural person, firm, association,
organization, partnership, business, trust, limited liability
company, corporation, or public entity.
2.3 At the time of the INCIDENT, did you have a driver's
license? If so state:
(a) the state or other issuing entity;
(b) the license number and type;
(c) the date of issuance; and
(d) all restrictions. (d) DOCUMENT means a writing, as defined in Evidence
Code section 250, and includes the original or a copy of
handwriting, typewriting, printing, photostats, photographs,
electronically stored information, and every other means of
recording upon any tangible thing and form of communicating
or representation, including letters, words, pictures, sounds, or
symbols, or combinations of them.
2.4 At the time of the INCIDENT, did you have any other
permit or license for the operation of a motor vehicle? If so,
state:
(e) HEALTH CARE PROVIDER includes any PERSON
referred to in Code of Civil Procedure section 667.7(e)(3).(a) the state or other issuing entity;
(b) the license number and type;
(c) the date of issuance; and
(d) all restrictions. (f) ADDRESS means the street address, including the city,
state, and zip code.
2.5 State:
Sec. 5. Interrogatories
(a) your present residence ADDRESS;
(b) your residence ADDRESSES for the past five years; and
(c) the dates you lived at each ADDRESS. The following interrogatories have been approved by the
Judicial Council under Code of Civil Procedure section 2033.710:
CONTENTS 2.6 State:
(a) the name, ADDRESS, and telephone number of your
present employer or place of self-employment; and 1.0 Identity of Persons Answering These Interrogatories
2.0 General Background Information—Individual
3.0 General Background Information—Business Entity
4.0 Insurance
5.0 [Reserved]
6.0 Physical, Mental, or Emotional Injuries
7.0 Property Damage
8.0 Loss of Income or Earning Capacity
9.0 Other Damages(b) the name, ADDRESS, dates of employment, job title,
and nature of work for each employer or
self-employment you have had from five years before
the INCIDENT until today.
2.7 State:
10.0 Medical History
11.0 Other Claims and Previous Claims
12.0 Investigation—General
13.0 Investigation—Surveillance
14.0 Statutory or Regulatory Violations
15.0 Denials and Special or Affirmative Defenses
16.0 Defendant’s Contentions Personal Injury
17.0 Responses to Request for Admissions
18.0 [Reserved]
19.0 [Reserved]
20.0 How the Incident Occurred—Motor Vehicle
25.0 [Reserved]
30.0 [Reserved]
40.0 [Reserved]
50.0 Contract
60.0 [Reserved](b) the dates you attended;
(c) the highest grade level you have completed; and
(d) the degrees received.
2.10 Can you read and write English with ease? If not, what
language and dialect do you normally use? 70.0 Unlawful Detainer [See separate form DISC-003]
101.0 Economic Litigation [See separate form DISC-004]
200.0 Employment Law [See separate form DISC-002]
Family Law [See separate form FL-145]
DISC-001 [Rev. January 1, 2008] FORM INTERROGATORIES—GENERAL Page 2 of 8
2.9 Can you speak English with ease? If not, what
language and dialect do you normally use? (a) the name and ADDRESS of each school or other
academic or vocational institution you have attended,
beginning with high school;
2.8 Have you ever been convicted of a felony? If so, for
each conviction state:
(a) the city and state where you were convicted;
(b) the date of conviction;
(c) the offense; and
(d) the court and case number.
DISC-001
3.4 Are you a joint venture? If so, state:
2.11 At the time of the INCIDENT were you acting as an
(a) the current joint venture name;
agent or employee for any PERSON? If so, state:
(b) all other names used by the joint venture during the
(a) the name, ADDRESS, and telephone number of that
PERSON: and past 10 years and the dates each was used;
(c) the name and ADDRESS of each joint venturer; and
(d) the ADDRESS of the principal place of business. (b) a description of your duties.
2.12 At the time of the INCIDENT did you or any other 3.5 Are you an unincorporated association?
person have any physical, emotional, or mental disability or
condition that may have contributed to the occurrence of the
INCIDENT? If so, for each person state:If so, state:
(a) the current unincorporated association name;
(b) all other names used by the unincorporated association
(a) the name, ADDRESS, and telephone number;
(b) the nature of the disability or condition; and
(c) the manner in which the disability or condition
contributed to the occurrence of the INCIDENT.during the past 10 years and the dates each was used;
and
(c) the ADDRESS of the principal place of business.
3.6 Have you done business under a fictitious name during 2.13 Within 24 hours before the INCIDENT did you or any
the past 10 years? If so, for each fictitious name state:
person involved in the INCIDENT use or take any of the
following substances: alcoholic beverage, marijuana, or
other drug or medication of any kind (prescription or not)? If
so, for each person state:(a) the name;
(b) the dates each was used;
(c) the state and county of each fictitious name filing; and
(d) the ADDRESS of the principal place of business.
(a) the name, ADDRESS, and telephone number;
(b) the nature or description of each substance;
(c) the quantity of each substance used or taken;
3.7 Within the past five years has any public entity regis-
(d) the date and time of day when each substance was used
tered or licensed your business? If so, for each license or
registration: or taken;
(e) the ADDRESS where each substance was used or
(a) identify the license or registration;
(b) state the name of the public entity; and
(c) state the dates of issuance and expiration. taken;
(f) the name, ADDRESS, and telephone number of each
person who was present when each substance was used
or taken; and
4.0 Insurance
(g) the name, ADDRESS, and telephone number of any
HEALTH CARE PROVIDER who prescribed or furnished
the substance and the condition for which it was
prescribed or furnished.
4.1 At the time of the INCIDENT, was there in effect any
policy of insurance through which you were or might be
insured in any manner (for example, primary, pro-rata, or
excess liability coverage or medical expense coverage) for
the damages, claims, or actions that have arisen out of the
INCIDENT? If so, for each policy state: 3.0 General Background Information—Business Entity
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;
(c) the name, ADDRESS, and telephone number of each
(c) the date and place of incorporation;
named insured;
(d) the ADDRESS of the principal place of business; and
(e) whether you are qualified to do business in California.(d) the policy number;
(e) the limits of coverage for each type of coverage con-
tained in the policy;
3.2 Are you a partnership? If so, state: (f) whether any reservation of rights or controversy or
(a) the current partnership name;
coverage dispute exists between you and the insurance
company; and
(b) all other names used by the partnership during the past
10 years and the dates each was used;
(g) the name, ADDRESS, and telephone number of the
custodian of the policy. (c) whether you are a limited partnership and, if so, under
the laws of what jurisdiction;
(d) the name and ADDRESS of each general partner; and
(e) the ADDRESS of the principal place of business.
3.3 Are you a limited liability company? If so, state:
5.0 [Reserved]
(a) the name stated in the current articles of organization;
(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;
(c) the date and place of filing of the articles of organization;
(d) the ADDRESS of the principal place of business; and
(e) whether you are qualified to do business in California.
6.2 Identify each injury you attribute to the INCIDENT and
the area of your body affected.
DISC-001 [Rev. January 1, 2008] FORM INTERROGATORIES—GENERAL Page 3 of 8
6.1 Do you attribute any physical, mental, or emotional
injuries to the INCIDENT? (If your answer is “no,” do not
answer interrogatories 6.2 through 6.7). 4.2 Are you self-insured under any statute for the damages,
claims, or actions that have arisen out of the INCIDENT? If
so, specify the statute.
DISC-001
(c) state the amount of damage you are claiming for each
6.3 Do you still have any complaints that you attribute to
the INCIDENT? If so, for each complaint state: item of property and how the amount was calculated; and
(d) if the property was sold, state the name, ADDRESS, and (a) a description;
(b) whether the complaint is subsiding, remaining the same, telephone number of the seller, the date of sale, and the
sale price. or becoming worse; and
(c) the frequency and duration.
6.4 Did you receive any consultation or examination
(except from expert witnesses covered by Code of Civil
Procedure sections 2034.210–2034.310) or treatment from a
HEALTH CARE PROVIDER for any injury you attribute to
the INCIDENT? If so, for each HEALTH CARE PROVIDER
state:7.2 Has a written estimate or evaluation been made for any
item of property referred to in your answer to the preceding
interrogatory? If so, for each estimate or evaluation state:
(a) the name, ADDRESS, and telephone number of the
PERSON who prepared it and the date prepared;
(b) the name, ADDRESS, and telephone number of each
PERSON who has a copy of it; and
(c) the amount of damage stated. (a) the name, ADDRESS, and telephone number;
(b) the type of consultation, examination, or treatment
provided;
(c) the dates you received consultation, examination, or
treatment; and
7.3 Has any item of property referred to in your answer to
interrogatory 7.1 been repaired? If so, for each item state:
(a) the date repaired;
(b) a description of the repair; (d) the charges to date.
(c) the repair cost; 6.5 Have you taken any medication, prescribed or not, as a
result of injuries that you attribute to the INCIDENT? If so,
for each medication state:(d) the name, ADDRESS, and telephone number of the
PERSON who repaired it;
(a) the name;
(e) the name, ADDRESS, and telephone number of the
PERSON who paid for the repair. (b) the PERSON who prescribed or furnished it;
(c) the date it was prescribed or furnished;
(d) the dates you began and stopped taking it; and
(e) the cost to date.8.0 Loss of Income or Earning Capacity
8.1 Do you attribute any loss of income or earning capacity
to the INCIDENT? (If your answer is “no,” do not answer
interrogatories 8.2 through 8.8). 6.6 Are there any other medical services necessitated by
the injuries that you attribute to the INCIDENT that were not
previously listed (for example, ambulance, nursing,
prosthetics)? If so, for each service state:
(a) the nature;
(b) the date;
8.2 State:
(a) the nature of your work;
(b) your job title at the time of the INCIDENT; and
(c) the date your employment began. (c) the cost; and
(d) the name, ADDRESS, and telephone number
of each provider.
8.3 State the last date before the INCIDENT that you
worked for compensation.
8.4 State your monthly income at the time of the INCIDENT
and how the amount was calculated. 6.7 Has any HEALTH CARE PROVIDER advised that you
may require future or additional treatment for any injuries
that you attribute to the INCIDENT? If so, for each injury
state:
8.5 State the date you returned to work at each place of
employment following the INCIDENT.
(b) the complaints for which the treatment was advised; and
(c) the nature, duration, and estimated cost of the
treatment.
8.6 State the dates you did not work and for which you lost
income as a result of the INCIDENT.
7.0 Property Damage
8.7 State the total income you have lost to date as a result
of the INCIDENT and how the amount was calculated.
7.1 Do you attribute any loss of or damage to a vehicle or
other property to the INCIDENT? If so, for each item of
property:
8.8 Will you lose income in the future as a result of the
INCIDENT? If so, state:
(a) the facts upon which you base this contention; (a) describe the property;
(b) describe the nature and location of the damage to the
property;(b) an estimate of the amount;
(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
(a) the name and ADDRESS of each HEALTH CARE
PROVIDER;
DISC-001
9.0 Other Damages
(c) the court, names of the parties, and case number of any
action filed;
(d) the name, ADDRESS, and telephone number of any
attorney representing you;
(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.
(d) the name, ADDRESS, and telephone number of each
PERSON to whom an obligation was incurred.
(a) the date, time, and place of the INCIDENT giving rise to 9.2 Do any DOCUMENTS support the existence or amount
of any item of damages claimed in interrogatory 9.1? If so,
describe each document and state the name, ADDRESS,
and telephone number of the PERSON who has each
DOCUMENT.the claim;
(b) the name, ADDRESS, and telephone number of your
employer at the time of the injury;
(c) the name, ADDRESS, 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;
(e) a description of the injury;
(f) the name, ADDRESS, and telephone number of any
HEALTH CARE PROVIDER who provided services; and
(g) the case number at the Workers’ Compensation Appeals
Board. (a) a description of the complaint or injury;
(b) the dates it began and ended; and
(c) the name, ADDRESS, and telephone number of each
12.0 Investigation—General
HEALTH CARE PROVIDER whom you consulted or
who examined or treated you.
12.1 State the name, ADDRESS, and telephone number of
each individual:
(a) who witnessed the INCIDENT or the events occurring 10.2 List all physical, mental, and emotional disabilities you
had immediately before the INCIDENT. (You may omit
mental or emotional disabilities unless you attribute any
mental or emotional injury to the INCIDENT.) immediately before or after the INCIDENT;
(b) who made any statement at the scene of the INCIDENT;
(c) who heard any statements made about the INCIDENT by
any individual at the scene; and
(d) who YOU OR ANYONE ACTING ON YOUR BEHALF
claim has knowledge of the INCIDENT (except for
expert witnesses covered by Code of Civil Procedure
section 2034).
(a) the date and the place it occurred;
(b) the name, ADDRESS, and telephone number of any
other PERSON involved;12.2 Have YOU OR ANYONE ACTING ON YOUR
BEHALF interviewed any individual concerning the
INCIDENT? If so, for each individual state: (c) the nature of any injuries you sustained;
(d) the name, ADDRESS, and telephone number of each
(a) the name, ADDRESS, and telephone number of the
individual interviewed;
(b) the date of the interview; and
(e) the nature of the treatment and its duration.
(c) the name, ADDRESS, and telephone number of the
PERSON who conducted the interview.
11.0 Other Claims and Previous Claims
(a) the date, time, and place and location (closest street
(a) the name, ADDRESS, and telephone number of the
individual from whom the statement was obtained; ADDRESS or intersection) of the INCIDENT giving rise
to the action, claim, or demand;
(b) the name, ADDRESS, and telephone number of the
individual who obtained the statement; (b) the name, ADDRESS, and telephone number of each
PERSON against whom the claim or demand was made
or the action filed;(c) the date the statement was obtained; and
(d) the name, ADDRESS, and telephone number of each
PERSON who has the original statement or a copy.
DISC-001 [Rev. January 1, 2008]
Page 5 of 8 FORM INTERROGATORIES—GENERAL
10.1 At any time before the INCIDENT did you have com-
plaints or injuries that involved the same part of your body
claimed to have been injured in the INCIDENT? If so, for
each state:
11.1 Except for this action, in the past 10 years have you
filed an action or made a written claim or demand for
compensation for your personal injuries? If so, for each
action, claim, or demand state:HEALTH CARE PROVIDER who you consulted or who
examined or treated you; and
12.3 Have YOU OR ANYONE ACTING ON YOUR
BEHALF obtained a written or recorded statement from any
individual concerning the INCIDENT? If so, for each
statement state: 11.2 In the past 10 years have you made a written claim or
demand for workers' compensation benefits? If so, for each
claim or demand state:
10.3 At any time after the INCIDENT, did you sustain
injuries of the kind for which you are now claiming
damages? If so, for each incident giving rise to an injury
state: 9.1 Are there any other damages that you attribute to the
INCIDENT? If so, for each item of damage state:
(a) the nature;
DISC-001
13.2 Has a written report been prepared on the
surveillance? If so, for each written report state:
(a) the title;
(b) the date; 12.4 Do YOU OR ANYONE ACTING ON YOUR BEHALF
know of any photographs, films, or videotapes depicting any
place, object, or individual concerning the INCIDENT or
plaintiff's injuries? If so, state:
(a) the number of photographs or feet of film or videotape;
(b) the places, objects, or persons photographed, filmed, or
videotaped;(d) the name, ADDRESS, and telephone number of each
PERSON who has the original or a copy.
(c) the date the photographs, films, or videotapes were
taken;
14.0 Statutory or Regulatory Violations
(d) the name, ADDRESS, and telephone number of the
14.1 Do YOU OR ANYONE ACTING ON YOUR BEHALF
contend that any PERSON involved in the INCIDENT
violated any statute, ordinance, or regulation and that the
violation was a legal (proximate) cause of the INCIDENT? If
so, identify the name, ADDRESS, and telephone number of
each PERSON and the statute, ordinance, or regulation that
was violated. (e) the name, ADDRESS, and telephone number of each
PERSON who has the original or a copy of the
photographs, films, or videotapes.
12.5 Do YOU OR ANYONE ACTING ON YOUR BEHALF
know of any diagram, reproduction, or model of any place or
thing (except for items developed by expert witnesses
covered by Code of Civil Procedure sections 2034.210–
2034.310) concerning the INCIDENT? If so, for each item
state:
14.2 Was any PERSON cited or charged with a violation of
any statute, ordinance, or regulation as a result of this
INCIDENT? If so, for each PERSON state:
(a) the name, ADDRESS, and telephone number of the
PERSON;
(b) the statute, ordinance, or regulation allegedly violated;
(c) whether the PERSON entered a plea in response to the
(c) the name, ADDRESS, and telephone number of each
PERSON who has it.citation or charge and, if so, the plea entered; and
(d) the name and ADDRESS of the court or administrative
agency, names of the parties, and case number. 12.6 Was a report made by any PERSON concerning the
INCIDENT? If so, state:
15.0 Denials and Special or Affirmative Defenses
(a) the name, title, identification number, and employer of
the PERSON who made the report;
15.1 Identify each denial of a material allegation and each
(b) the date and type of report made;special or affirmative defense in your pleadings and for
each:
(c) the name, ADDRESS, and telephone number of the
PERSON for whom the report was made; and(a) state all facts upon which you base the denial or special
(d) the name, ADDRESS, and telephone number of each
PERSON who has the original or a copy of the report.or affirmative defense;
(b) state the names, ADDRESSES, and telephone numbers
of all PERSONS who have knowledge of those facts;
and
(c) identify all DOCUMENTS and other tangible things that 12.7 Have YOU OR ANYONE ACTING ON YOUR
BEHALF inspected the scene of the INCIDENT? If so, for
each inspection state:support your denial or special or affirmative defense, and
state the name, ADDRESS, and telephone number of
the PERSON who has each DOCUMENT. (a) the name, ADDRESS, and telephone number of the
individual making the inspection (except for expert
witnesses covered by Code of Civil Procedure
sections 2034.210–2034.310); and16.0 Defendant’s Contentions—Personal Injury
(b) the date of the inspection.
13.0 Investigation—Surveillance
(a) state the name, ADDRESS, and telephone number of
the PERSON; 13.1 Have YOU OR ANYONE ACTING ON YOUR BEHALF
conducted surveillance of any individual involved in the
INCIDENT or any party to this action? If so, for each sur-
veillance state:(b) state all facts upon which you base your contention;
(c) state the names, ADDRESSES, and telephone numbers
of all PERSONS who have knowledge of the facts; and
(a) the name, ADDRESS, and telephone number of the
individual or party;(d) identify all DOCUMENTS and other tangible things that
support your contention and state the name, ADDRESS,
and telephone number of the PERSON who has each
DOCUMENT or thing. (b) the time, date, and place of the surveillance;
(c) the name, ADDRESS, and telephone number of the
individual who conducted the surveillance; and
(d) the name, ADDRESS, and telephone number of each
PERSON who has the original or a copy of any
surveillance photograph, film, or videotape.
(c) identify all DOCUMENTS and other tangible things that
support your contention and state the name, ADDRESS,
and telephone number of the PERSON who has each
DOCUMENT or thing.
DISC-001 [Rev. January 1, 2008]
Page 6 of 8 FORM INTERROGATORIES—GENERAL
individual taking the photographs, films, or videotapes;
and
(a) the type (i.e., diagram, reproduction, or model);
(b) the subject matter; and
16.2 Do you contend that plaintiff was not injured in the
INCIDENT? If so:
(a) state all facts upon which you base your contention;
(b) state the names, ADDRESSES, and telephone numbers
of all PERSONS who have knowledge of the facts; and 16.1 Do you contend that any PERSON, other than you or
plaintiff, contributed to the occurrence of the INCIDENT or
the injuries or damages claimed by plaintiff? If so, for each
PERSON:(c) the name, ADDRESS, and telephone number of the
individual who prepared the report; and
DISC-001
16.8 Do you contend that any of the costs of repairing the
property damage claimed by plaintiff in discovery
proceedings thus far in this case were unreasonable? If so:
(a) identify each cost item;
(a) identify it;
(b) state all facts upon which you base your contention;
(c) state the names, ADDRESSES, and telephone numbers
of all PERSONS who have knowledge of the facts; and(b) state all facts upon which you base your contention;
(c) state the names, ADDRESSES, and telephone numbers
of all PERSONS who have knowledge of the facts; and
(d) identify all DOCUMENTS and other tangible things that
(d) identify all DOCUMENTS and other tangible things that
support your contention and state the name, ADDRESS,
and telephone number of the PERSON who has each
DOCUMENT or thing. support your contention and state the name, ADDRESS,
and telephone number of the PERSON who has each
DOCUMENT or thing.
(a) identify each service;
(b) state all facts upon which you base your contention;
(c) state the names, ADDRESSES, and telephone numbers
of all PERSONS who have knowledge of the facts; and(a) the source of each DOCUMENT;
(b) the date each claim arose;
(c) the nature of each claim; and
(d) the name, ADDRESS, and telephone number of the
PERSON who has each DOCUMENT. (d) identify all DOCUMENTS and other tangible things that
support your contention and state the name, ADDRESS,
and telephone number of the PERSON who has each
DOCUMENT or thing.
16.10 Do YOU OR ANYONE ACTING ON YOUR BEHALF
have any DOCUMENT concerning the past or present
physical, mental, or emotional condition of any plaintiff in
this case from a HEALTH CARE PROVIDER not previously
identified (except for expert witnesses covered by Code of
Civil Procedure sections 2034.210–2034.310)? If so, for
each plaintiff state:
(a) identify each cost;
(a) the name, ADDRESS, and telephone number of each
HEALTH CARE PROVIDER; (b) state all facts upon which you base your contention;
(c) state the names, ADDRESSES, and telephone numbers
of all PERSONS who have knowledge of the facts; and(b) a description of each DOCUMENT; and
(c) the name, ADDRESS, and telephone number of the
PERSON who has each DOCUMENT. (d) identify all DOCUMENTS and other tangible things that
support your contention and state the name, ADDRESS,
and telephone number of the PERSON who has each
DOCUMENT or thing.17.0 Responses to Request for Admissions
17.1 Is your response to each request for admission served
with these interrogatories an unqualified admission? If not,
for each response that is not an unqualified admission:
(a) state the number of the request;
(b) state all facts upon which you base your response;
(a) identify each part of the loss;
(b) state all facts upon which you base your contention;
(c) state the names, ADDRESSES, and telephone numbers
of all PERSONS who have knowledge of the facts; and(c) state the names, ADDRESSES, and telephone numbers
of all PERSONS who have knowledge of those facts;
and
(d) identify all DOCUMENTS and other tangible things that
support your response and state the name, ADDRESS,
and telephone number of the PERSON who has each
DOCUMENT or thing. (d) identify all DOCUMENTS and other tangible things that
support your contention and state the name, ADDRESS,
and telephone number of the PERSON who has each
DOCUMENT or thing.
18.0 [Reserved]
19.0 [Reserved] 16.7 Do you contend that any of the property damage
claimed by plaintiff in discovery Proceedings thus far in this
case was not caused by the INCIDENT? If so:
20.0 How the Incident Occurred—Motor Vehicle
(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;
(c) state the names, ADDRESSES, and telephone numbers
of all PERSONS who have knowledge of the facts; and(closest street ADDRESS or intersection).
(d) identify all DOCUMENTS and other tangible things that20.2 For each vehicle involved in the INCIDENT, state:
support your contention and state the name, ADDRESS,
and telephone number of the PERSON who has each
DOCUMENT or thing.(a) the year, make, model, and license number;
(b) the name, ADDRESS, and telephone number of the
driver;
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Page 7 of 8 FORM INTERROGATORIES—GENERAL
16.3 Do you contend that the injuries or the extent of the
injuries claimed by plaintiff as disclosed in discovery
proceedings thus far in this case were not caused by the
INCIDENT? If so, for each injury:
16.4 Do you contend that any of the services furnished by
any HEALTH CARE PROVIDER claimed by plaintiff in
discovery proceedings thus far in this case were not due to
the INCIDENT? If so:
16.5 Do you contend that any of the costs of services
furnished by any HEALTH CARE PROVIDER claimed as
damages by plaintiff in discovery proceedings thus far in
this case were not necessary or unreasonable? If so:
16.6 Do you contend that any part of the loss of earnings or
income claimed by plaintiff in discovery proceedings thus far
in this case was unreasonable or was not caused by the
INCIDENT? If so:16.9 Do YOU OR ANYONE ACTING ON YOUR BEHALF
have any DOCUMENT (for example, insurance bureau
index reports) concerning claims for personal injuries made
before or after the INCIDENT by a plaintiff in this case? If
so, for each plaintiff state:
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(d) state the name, ADDRESS, and telephone number of
each PERSON who has custody of each defective part. (c) the name, ADDRESS, and telephone number of each
occupant other than the driver;
(d) the name, ADDRESS, and telephone number of each
registered owner;
20.11 State the name, ADDRESS, and telephone number of
each owner and each PERSON who has had possession
since the INCIDENT of each vehicle involved in the
INCIDENT. (e) the name, ADDRESS, and telephone number of each
lessee;
(f) the name, ADDRESS, and telephone number of each
25.0 [Reserved]
(g) the name of each owner who gave permission or
consent to the driver to operate the vehicle.30.0 [Reserved]
40.0 [Reserved]
50.0 Contract
50.1 For each agreement alleged in the pleadings:
(a) identify each DOCUMENT that is part of the agreement
and for each state the name, ADDRESS, and telephone
number of each PERSON who has the DOCUMENT;
(b) state each part of the agreement not in writing, the
(c) identify all DOCUMENTS that evidence any part of the
agreement not in writing and for each state the name,
ADDRESS, and telephone number of each PERSON
who has the DOCUMENT;
(d) identify all DOCUMENTS that are part of any
modification to the agreement, and for each state the
name, ADDRESS, and telephone number of each
PERSON who has the DOCUMENT;
20.7 Was there a traffic signal facing you at the time of the
INCIDENT? If so, state:
(a) your location when you first saw it;
(e) state each modification not in writing, the date, and the
(b) the color;
name, ADDRESS, and telephone number of each
PERSON agreeing to the modification, and the date the
modification was made; (c) the number of seconds it had been that color; and
(d) whether the color changed between the time you first
saw it and the INCIDENT.
(f) identify all DOCUMENTS that evidence any modification
of the agreement not in writing and for each state the
name, ADDRESS, and telephone number of each
PERSON who has the DOCUMENT.
20.8 State how the INCIDENT occurred, giving the speed,
direction, and location of each vehicle involved:
(a) just before the INCIDENT;
(b) at the time of the INCIDENT; and (c) just
after the INCIDENT.
(a) identify the vehicle;
(b) identify each malfunction or defect;
(c) state the name, ADDRESS, and telephone number of
(d) state the name, ADDRESS, and telephone number of
each PERSON who has custody of each defective part.
(a) identify the vehicle;
(b) identify each malfunction or defect;
(c) state the name, ADDRESS, and telephone number of
each PERSON who is a witness to or has information
about each malfunction or defect; and60.0 [Reserved]
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Page 8 of 8 FORM INTERROGATORIES—GENERAL
20.9 Do you have information that a malfunction or defect in
a vehicle caused the INCIDENT? If so:
20.10 Do you have information that any malfunction or
defect in a vehicle contributed to the injuries sustained in the
INCIDENT? If so: 20.6 Did the INCIDENT occur at an intersection? If so,
describe all traffic control devices, signals, or signs at the
intersection. 20.5 State the name of the street or roadway, the lane of
travel, and the direction of travel of each vehicle involved in
the INCIDENT for the 500 feet of travel before the
INCIDENT. 20.4 Describe the route that you followed from the
beginning of your trip to the location of the INCIDENT, and
state the location of each stop, other than routine traffic
stops, during the trip leading up to the INCIDENT. 20.3 State the ADDRESS and location where your trip
began and the ADDRESS and location of your destination. owner other than the registered owner or lien holder;
and
50.6 Is any agreement alleged in the pleadings ambiguous?
If so, identify each ambiguous agreement and state why it is
ambiguous. 50.5 Is any agreement alleged in the pleadings unenforce-
able? If so, identify each unenforceable agreement and
state why it is unenforceable. 50.4 Was any agreement alleged in the pleadings terminated
by mutual agreement, release, accord and satisfaction, or
novation? If so, identify each agreement terminated, the date
of termination, and the basis of the termination. 50.3 Was performance of any agreement alleged in the
pleadings excused? If so, identify each agreement excused
and state why performance was excused. 50.2 Was there a breach of any agreement alleged in the
pleadings? If so, for each breach describe and give the date
of every act or omission that you claim is the breach of the
agreement.name, ADDRESS, and telephone number of each
PERSON agreeing to that provision, and the date that
part of the agreement was made;
each PERSON who is a witness to or has information
about each malfunction or defect; and
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