DISC-001
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
–––––
–––––
–––––
TELEPHONE NO.: –––––
FAX NO. (Optional): –––––
E-MAIL ADDRESS (Optional): –––––
ATTORNEY FOR (Name): –––––
SUPERIOR COURT OF CALIFORNIA, COUNTY OF –––––
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SHORT TITLE OF CASE: –––––
FORM INTERROGATORIES—GENERAL CASE NUMBER:
Asking Party: –––––
Answering Party: ––––– –––––
Set No.: –––––
Sec. 1. Instructions to All Parties (c) Each answer must be as complete and straightforward
(a) Interrogatories are written questions prepared by a party as the information reasonably available to you, including the
to an action that are sent to any other party in the action to be information possessed by your attorneys or agents, permits. If
answered under oath. The interrogatories below are form an interrogatory cannot be answered completely, answer it to
interrogatories approved for use in civil cases. the extent possible.
(b) For time limitations, requirements for service on other (d) If you do not have enough personal knowledge to fully
parties, and other details, see Code of Civil Procedure answer an interrogatory, say so, but make a reasonable and
sections 2030.010–2030.410 and the cases construing those good faith effort to get the information by asking other persons
sections. or organizations, unless the information is equally available to
(c) These form interrogatories do not change existing law the asking party.
relating to interrogatories nor do they affect an answering
party’s right to assert any privilege or make any objection. (e) Whenever an interrogatory may be answered by
referring to a document, the document may be attached as an
Sec. 2. Instructions to the Asking Party 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
(a) These interrogatories are designed for optional use by can be found.
parties in unlimited civil cases where the amount demanded
exceeds $25,000. Separate interrogatories, Form (f) Whenever an address and telephone number for the
Interrogatories—Economic Litigation (form DISC-004 which have same person are requested in more than one interrogatory,
no subparts, are designed for use in limited civil cases where you are required to furnish them in answering only the first
the amount demanded is $25,000 or less; however, those interrogatory asking for that information.
interrogatories may also be used in unlimited civil cases. (g) If you are asserting a privilege or making an objection to
(b) Check the box next to each interrogatory that you want an interrogatory, you must specifically assert the privilege or
the answering party to answer. Use care in choosing those state the objection in your written response.
interrogatories that are applicable to the case. (h) Your answers to these interrogatories must be verified,
(c) You may insert your own definition of INCIDENT in dated, and signed. You may wish to use the following form at
Section 4, but only where the action arises from a course of the end of your answers:
conduct or a series of events occurring over a period of time.
I declare under penalty of perjury under the laws of the
(d) The interrogatories in section 16.0, Defendant’s State of California that the foregoing answers are true and
Contentions–Personal Injury, should not be used until the correct.
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. 3. Instructions to the Answering Party Sec. 4. Definitions
(a) An answer or other appropriate response must be Words in BOLDFACE CAPITALS in these interrogatories
given to each interrogatory checked by the asking party. are defined as follows:
(b) As a general rule, within 30 days after you are served (a) (Check one of the following):
with these interrogatories, you must serve your responses on (1) INCIDENT includes the circumstances and
the asking party and serve copies of your responses on all events surrounding the alleged accident, injury, or
other parties to the action who have appeared. See Code of other occurrence or breach of contract giving rise to
Civil Procedure sections 2030.260–2030.270 for details. this action or proceeding. Page 1 of 8
Form Approved for Optional Use Code of Civil Procedure,
FORM INTERROGATORIES—GENERAL electronic form ã 2005
WWW.LawCA.co
m
Law Publishers
Judicial Council of California §§ 2030.010-2030.410, 2033.710
DISC-001 [Rev. January 1, 2007]
DISC-001
(2) INCIDENT means (insert your definition here or 1.0 Identity of Persons Answering These Interrogatories
on a separate, attached sheet labeled “Sec. 1.1 State the name, ADDRESS, telephone number, and
4(a)(2)”): 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 2.1 State:
includes you, your agents, your employees, your insurance (a) your name;
companies, their agents, their employees, your attorneys, your (b) every name you have used in the past; and
accountants, your investigators, and anyone else acting on (c) the dates you used each name.
your behalf.
(c) PERSON includes a natural person, firm, association, 2.2 State the date and place of your birth.
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:
(d) DOCUMENT means a writing, as defined in Evidence (a) the state or other issuing entity;
Code section 250, and includes the original or a copy of (b) the license number and type;
handwriting, typewriting, printing, photostats, photographs, (c) the date of issuance; and
electronically stored information, and every other means of (d) all restrictions.
recording upon any tangible thing and form of communicating
or representation, including letters, words, pictures, sounds, or 2.4 At the time of the INCIDENT, did you have any other
symbols, or combinations of them. permit or license for the operation of a motor vehicle? If
so, state:
(e) HEALTH CARE PROVIDER includes any PERSON (a) the state or other issuing entity;
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 (b) your residence ADDRESSES for the past five years; and
Judicial Council under Code of Civil Procedure section 2033.710: (c) the dates you lived at each ADDRESS.
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 Information—Business Entity (b) the name, ADDRESS, dates of employment, job title,
4.0 Insurance and nature of work for each employer or
5.0 [Reserved] self-employment you have had from five years before
6.0 Physical, Mental, or Emotional Injuries 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 Regulatory 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 where you were convicted;
19.0 [Reserved] (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?
60.0 [Reserved]
70.0 Unlawful Detainer [See separate form Fl-128] 2.10 Can you read and write English with ease? If not, what
101.0 Economic Litigation [See separate form Fl-129] language and dialect do you normally use?
200.0 Employment Law [See separate form Fl-130]
Family Law [See separate form 1292.10]
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2.11 At the time of the INCIDENT were you acting as an 3.4 Are you a joint venture? If so, state:
agent or employee for any PERSON? If so, state: (a) the current joint venture name;
(a) the name, ADDRESS, and telephone number of that (b) all other names used by the joint venture during the
PERSON: and past 10 years and the dates each was used;
(b) a description of your duties. (c) the name and ADDRESS of each joint venturer; and
(d) the ADDRESS of the principal place of business.
2.12 At the time of the INCIDENT did you or any other
person have any physical, emotional, or mental disability or 3.5 Are you an unincorporated association?
condition that may have contributed to the occurrence of the If so, state:
INCIDENT? If so, for each person state: (a) the current unincorporated association name;
(a) the name, ADDRESS, and telephone number; (b) all other names used by the unincorporated association
(b) the nature of the disability or condition; and during the past 10 years and the dates each was used;
(c) the manner in which the disability or condition and
contributed to the occurrence of the INCIDENT. (c) the ADDRESS of the principal place of business.
2.13 Within 24 hours before the INCIDENT did you or any 3.6 Have you done business under a fictitious name during
person involved in the INCIDENT use or take any of the the past 10 years? If so, for each fictitious name state:
following substances: alcoholic beverage, marijuana, or (a) the name;
other drug or medication of any kind (prescription or not)? If (b) the dates each was used;
so, for each person state: (c) the state and county of each fictitious name filing; and
(a) the name, ADDRESS, and telephone number; (d) the ADDRESS of the principal place of business.
(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
or taken; registration:
(e) the ADDRESS where each substance was used or (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
(g) the name, ADDRESS, and telephone number of any 4.0 Insurance
HEALTH CARE PROVIDER who prescribed or furnished 4.1 At the time of the INCIDENT, was there in effect any
the substance and the condition for which it was 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 that have arisen out of the
3.1 Are you a corporation? If so, state: INCIDENT? If so, for each policy state:
(a) the name stated in the current articles of incorporation; (a) the kind of coverage;
(b) all other names used by the corporation during the past (b) the name and ADDRESS of the insurance company;
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 (d) the policy number;
(e) whether you are qualified to do business in California. (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
(b) all other names used by the partnership during the past company; and
10 years and the dates each was used; (g) the name, ADDRESS, and telephone number of the
(c) whether you are a limited partnership and, if so, under custodian of the policy.
the laws of what jurisdiction;
(d) the name and ADDRESS of each general partner; and 4.2 Are you self-insured under any statute for the damages,
(e) the ADDRESS of the principal place of business. claims, or actions that have arisen out of the INCIDENT? If
so, specify the statute.
3.3 Are you a limited liability company? If so, state:
(a) the name stated in the current articles of organization; 5.0 [Reserved]
(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; 6.1 Do you attribute any physical, mental, or emotional
(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 you attribute to the INCIDENT
and the area of your body affected.
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6.3 Do you still have any complaints that you attribute to (c) state the amount of damage you are claiming for each
the INCIDENT? If so, for each complaint state: item of property and how the amount was calculated; and
(a) a description; (d) if the property was sold, state the name, ADDRESS, and
(b) whether the complaint is subsiding, remaining the same, 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:
HEALTH CARE PROVIDER for any injury you attribute to
the INCIDENT? If so, for each HEALTH CARE PROVIDER (a) the name, ADDRESS, and telephone number of the
state: PERSON who prepared it and the date prepared;
(b) the name, ADDRESS, and telephone number of each
(a) the name, ADDRESS, and telephone number; PERSON who has a copy of it; and
(b) the type of consultation, examination, or treatment (c) the amount of damage stated.
provided;
(c) the dates you received consultation, examination, or
treatment; and 7.3 Has any item of property referred to in your answer to
(d) the charges to date. interrogatory 7.1 been repaired? If so, for each item state:
(a) the date repaired;
6.5 Have you taken any medication, prescribed or not, as a (b) a description of the repair;
result of injuries that you attribute to the INCIDENT? If so, (c) the repair cost;
for each medication state: (d) the name, ADDRESS, and telephone number of the
(a) the name; PERSON who repaired it;
(b) the PERSON who prescribed or furnished it; (e) the name, ADDRESS, and telephone number of the
(c) the date it was prescribed or furnished; PERSON who paid for the repair.
(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
6.6 Are there any other medical services necessitated by to the INCIDENT ? (If your answer is “no,” do not answer
the injuries that you attribute to the INCIDENT that were not interrogatories 8.2 through 8.8).
previously listed (for example, ambulance, nursing,
prosthetics)? If so, for each service state: 8.2 State:
(a) the nature;
(b) the date; (a) the nature of your work;
(b) your job title at the time of the INCIDENT; and
(c) the cost; and (c) the date your employment began.
(d) the name, ADDRESS, and telephone number
of each provider. 8.3 State the last date before the INCIDENT that you
worked for compensation.
6.7 Has any HEALTH CARE PROVIDER advised that you
may require future or additional treatment for any injuries 8.4 State your monthly income at the time of the INCIDENT
that you attribute to the INCIDENT? If so, for each injury and how the amount was calculated.
state:
(a) the name and ADDRESS of each HEALTH CARE 8.5 State the date you returned to work at each place of
PROVIDER; employment following the INCIDENT.
(b) the complaints for which the treatment was advised; and
(c) the nature, duration, and estimated cost of the 8.6 State the dates you did not work and for which you lost
treatment. 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
7.1 Do you attribute any loss of or damage to a vehicle or of the INCIDENT and how the amount was calculated.
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
(a) describe the property; INCIDENT? If so, state:
(b) describe the nature and location of the damage to the (a) the facts upon which you base this contention;
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.
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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;
(b) the date it occurred; (e) whether the claim or action has been resolved or is
(c) the amount; and pending; and
(d) the name, ADDRESS, and telephone number of each (f) a description of the injury.
PERSON to whom an obligation was incurred.
11.2 In the past 10 years have you made a written claim or
demand for workers' compensation benefits? If so, for each
9.2 Do any DOCUMENTS support the existence or amount claim or demand state:
of any item of damages claimed in interrogatory 9.1? If so, (a) the date, time, and place of the INCIDENT giving rise to
describe each document and state the name, ADDRESS, the claim;
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;
(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’
10.1 At any time before the INCIDENT did you have com- compensation benefits;
plaints or injuries that involved the same part of your body (e) a description of the injury;
claimed to have been injured in the INCIDENT? If so, for (f) the name, ADDRESS, and telephone number of any
each state: HEALTH CARE PROVIDER who provided services; and
(a) a description of the complaint or injury; (g) the case number at the Workers’ Compensation Appeals
(b) the dates it began and ended; and Board.
(c) the name, ADDRESS, and telephone number of each
HEALTH CARE PROVIDER whom you consulted or 12.0 Investigation—General
who examined or treated you. 12.1 State the name, ADDRESS, and telephone number of
each individual:
10.2 List all physical, mental, and emotional disabilities you (a) who witnessed the INCIDENT or the events occurring
had immediately before the INCIDENT. (You may omit immediately before or after the INCIDENT;
mental or emotional disabilities unless you attribute any (b) who made any statement at the scene of the INCIDENT;
mental or emotional injury to the INCIDENT. ) (c) who heard any statements made about the INCIDENT
by any individual at the scene; and
10.3 At any time after the INCIDENT, did you sustain (d) who YOU OR ANYONE ACTING ON YOUR BEHALF
injuries of the kind for which you are now claiming claim has knowledge of the INCIDENT (except for
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
other PERSON involved; 12.2 Have YOU OR ANYONE ACTING ON
YOUR BEHALF interviewed any individual
(c) the nature of any injuries you sustained; concerning the 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
HEALTH CARE PROVIDER who you consulted or who individual interviewed;
examined or treated you; and
(e) the nature of the treatment and its duration. (b) the date of the interview; and
(c) the name, ADDRESS, and telephone number of the
11.0 Other Claims and Previous Claims PERSON who conducted the interview.
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 BEHALF obtained a written or recorded statement from any
compensation for your personal injuries? If so, for each individual concerning the INCIDENT? If so, for each
action, claim, or demand state: statement state:
(a) the date, time, and place and location (closest street (a) the name, ADDRESS, and telephone number of the
ADDRESS or intersection) of the INCIDENT giving rise individual from whom the statement was obtained;
to the action, claim, or demand; (b) the name, ADDRESS, and telephone number of the
(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
PERSON who has the original statement or a copy.
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12.4 Do YOU OR ANYONE ACTING ON YOUR BEHALF 13.2 Has a written report been prepared on the
know of any photographs, films, or videotapes depicting any surveillance? If so, for each written report state:
place, object, or individual concerning the INCIDENT or (a) the title;
plaintiff's injuries? If so, state: (b) the date;
(a) the number of photographs or feet of film or videotape; (c) the name, ADDRESS, and telephone number of the
(b) the places, objects, or persons photographed, filmed, or individual who prepared the report; and
videotaped; (d) the name, ADDRESS, and telephone number of each
(c) the date the photographs, films, or videotapes were PERSON who has the original or a copy.
(d) taken; 14.0 Statutory or Regulatory Violations
the name, ADDRESS, and telephone number of the
individual taking the photographs, films, or videotapes; 14.1 Do YOU OR ANYONE ACTING ON YOUR BEHALF
and contend that any PERSON involved in the INCIDENT
(e) the name, ADDRESS, and telephone number of each violated any statute, ordinance, or regulation and that the
PERSON who has the original or a copy of the violation was a legal (proximate) cause of the INCIDENT? If
photographs, films, or videotapes. so, identify the name, ADDRESS, and telephone number of
each PERSON and the statute, ordinance, or regulation
that
12.5 Do YOU OR ANYONE ACTING ON YOUR BEHALF was violated.
know of any diagram, reproduction, or model of any place or
thing (except for items developed by expert witnesses 14.2 Was any PERSON cited or charged with a violation of
covered by Code of Civil Procedure sections 2034.210– any statute, ordinance, or regulation as a result of this
2034.310) concerning the INCIDENT? If so, for each item INCIDENT? If so, for each PERSON state:
state: (a) the name, ADDRESS, and telephone number of the
(a) the type (i.e., diagram, reproduction, or model); PERSON
(b) the subject matter; and (b) the statute, ordinance, or regulation allegedly violated;
(c) the name, ADDRESS, and telephone number of each (c) whether the PERSON entered a plea in response to the
PERSON who has it. citation or charge and, if so, the plea entered; and
(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.
INCIDENT? If so, state:
(a) the name, title, identification number, and employer of 15.0 Denials and Special or Affirmative Defenses
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
(c) the name, ADDRESS, and telephone number of the each:
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 or affirmative defense;
PERSON who has the original or a copy of the report. (b) state the names, ADDRESSES, and telephone
numbers of all PERSONS who have knowledge of
those facts; and
12.7 Have YOU OR ANYONE ACTING ON YOUR (c) identify all DOCUMENTS and other tangible things that
BEHALF inspected the scene of the INCIDENT? If so, for support your denial or special or affirmative defense, and
each inspection state: state the name, ADDRESS, and telephone number of
(a) the name, ADDRESS, and telephone number of the the PERSON who has each DOCUMENT.
individual making the inspection (except for expert
witnesses covered by Code of Civil Procedure 16.0 Defendant’s Contentions—Personal Injury
sections 2034.210–2034.310); and 16.1 Do you contend that any PERSON, other than you or
(b) the date of the inspection. plaintiff, contributed to the occurrence of the INCIDENT
or the injuries or damages claimed by plaintiff? If so, for
each PERSON:
13.0 Investigation—Surveillance (a) state the name, ADDRESS, and telephone number of
13.1 Have YOU OR ANYONE ACTING ON YOUR BEHALF the PERSON;
conducted surveillance of any individual involved in the (b) state all facts upon which you base your contention;
INCIDENT or any party to this action? If so, for each sur- (c) state the names, ADDRESSES, and telephone numbers
veillance state: of all PERSONS who have knowledge of the facts; and
(a) the name, ADDRESS, and telephone number of the (d) identify all DOCUMENTS and other tangible things that
individual or party; support your contention and state the name, ADDRESS,
and telephone number of the PERSON who has each
(b) the time, date, and place of the surveillance; DOCUMENT or thing.
(c) the name, ADDRESS, and telephone number of the
individual who conducted the surveillance; and the 16.2 Do you contend that plaintiff was not injured in
(d) the name, ADDRESS, and telephone number of each INCIDENT? If so:
PERSON who has the original or a copy of any (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 PERSONS who have knowledge of the facts; and
(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.
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16.3 Do you contend that the injuries or the extent of the 16.8 Do you contend that any of the costs of repairing the
injuries claimed by plaintiff as disclosed in discovery property damage claimed by plaintiff in discovery
proceedings thus far in this case were not caused by the proceedings thus far in this case were unreasonable? If so:
INCIDENT ? If so, for each injury: (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; (c) state the names, ADDRESSES, and telephone numbers
(c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and
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,
support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each
and telephone number of the PERSON who has each DOCUMENT or thing.
DOCUMENT or thing.
16.4 Do you contend that any of the services furnished by 16.9 Do YOU OR ANYONE ACTING ON YOUR BEHALF
any HEALTH CARE PROVIDER claimed by plaintiff in have any DOCUMENT (for example, insurance bureau
discovery proceedings thus far in this case were not due to index reports) concerning claims for personal injuries made
the INCIDENT ? If so: before or after the INCIDENT by a plaintiff in this case?
If so, for each plaintiff state:
(a) identify each service;
(b) state all facts upon which you base your contention; (a) the source of each DOCUMENT;
(c) state the names, ADDRESSES, and telephone numbers (b) the date each claim arose;
of all PERSONS who have knowledge of the facts; and (c) the nature of each claim; and
(d) identify all DOCUMENTS and other tangible things that (d) the name, ADDRESS, and telephone number of the
support your contention and state the name, ADDRESS, PERSON who has each DOCUMENT.
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
16.5 Do you contend that any of the costs of services this case from a HEALTH CARE PROVIDER not previously
furnished by any HEALTH CARE PROVIDER claimed as identified (except for expert witnesses covered by Code of
damages by plaintiff in discovery proceedings thus far in Civil Procedure sections 2034.210–2034.310)? If so, for
this case were not necessary or unreasonable? If so: each plaintiff state:
(a) identify each cost;
(a) the name, ADDRESS, and telephone number of each
(b) state all facts upon which you base your contention; HEALTH CARE PROVIDER;
(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
(d) identify all DOCUMENTS and other tangible things that (c) the name, ADDRESS, and telephone number of the
support your contention and state the name, ADDRESS, PERSON who has each DOCUMENT.
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
16.6 Do you contend that any part of the loss of earnings or with these interrogatories an unqualified admission? If not,
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; (c) state the names, ADDRESSES, and telephone numbers
(b) state all facts upon which you base your contention; of all PERSONS who have knowledge of those facts;
(c) state the names, ADDRESSES, and telephone numbers and
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 response and state the name, ADDRESS,
support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each
and telephone number of the PERSON who has each DOCUMENT or thing.
DOCUMENT or thing.
18.0
[Reserved]
16.7 Do you contend that any of the property damage
claimed by plaintiff in discovery Proceedings thus far in this 19.0 [Reserved]
case was not caused by the INCIDENT ? If so: 20.0 How the Incident Occurred—Motor Vehicle
(a) identify each item of property damage;
(b) state all facts upon which you base your contention; 20.1 State the date, time, and place of the INCIDENT
(c) state the names, ADDRESSES, and telephone numbers (closest street ADDRESS or intersection).
of all PERSONS who have knowledge of the facts; and
(d) identify all DOCUMENTS and other tangible things that 20.2 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 (a) the year, make, model, and license number;
DOCUMENT or thing. (b) the name, ADDRESS, and telephone number of
the driver;
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DISC-001
(c) the name, ADDRESS, and telephone number of each (d) state the name, ADDRESS, and telephone number of
occupant other than the driver; each PERSON who has custody of each defective part.
(d) the name, ADDRESS, and telephone number of each
registered owner; 20.11 State the name, ADDRESS, and telephone number of
(e) the name, ADDRESS, and telephone number of each each owner and each PERSON who has had possession
lessee; since the INCIDENT of each vehicle involved in the
(f) the name, ADDRESS, and telephone number of each INCIDENT.
owner other than the registered owner or lien holder;
and 25.0 [Reserved]
(g) the name of each owner who gave permission or 30.0 [Reserved]
consent to the driver to operate the vehicle.
40.0
[Reserved]
20.3 State the ADDRESS and location where your trip
began and the ADDRESS and location of your destination. 50.0 Contract
20.4 Describe the route that you followed from the 50.1 For each agreement alleged in the pleadings:
beginning of your trip to the location of the INCIDENT, and (a) identify each DOCUMENT that is part of the agreement
state the location of each stop, other than routine traffic and for each state the name, ADDRESS, and telephone
stops, during the trip leading up to the INCIDENT. number of each PERSON who has the DOCUMENT;
(b) state each part of the agreement not in writing, the
20.5 State the name of the street or roadway, the lane of name, ADDRESS, and telephone number of each
travel, and the direction of travel of each vehicle involved in PERSON agreeing to that provision, and the date that
the INCIDENT for the 500 feet of travel before the part of the agreement was made;
INCIDENT. (c) identify all DOCUMENTS that evidence any part of the
20.6 Did the INCIDENT occur at an intersection? If so, agreement not in writing and for each state the name,
describe all traffic control devices, signals, or signs at the ADDRESS, and telephone number of each PERSON
intersection. 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
20.7 Was there a traffic signal facing you at the time of the each PERSON who has the DOCUMENT;
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
(c) the number of seconds it had been that color; and PERSON agreeing to the modification, and the date the
(d) whether the color changed between the time you first modification was made;
saw it and the INCIDENT. (f) identify all DOCUMENTS that evidence any
modification of the agreement not in writing and for
each state the
20.8 State how the INCIDENT occurred, giving the speed, name, ADDRESS, and telephone number of each
direction, and location of each vehicle involved: PERSON who has the DOCUMENT.
(a) just before the INCIDENT;
(b) at the time of the INCIDENT; and (c) just 50.2 Was there a breach of any agreement alleged in the
after the INCIDENT. 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.
20.9 Do you have information that a malfunction or defect in
a vehicle caused the INCIDENT ? If so: 50.3 Was performance of any agreement alleged in the
(a) identify the vehicle; pleadings excused? If so, identify each agreement excused
(b) identify each malfunction or defect; and state why performance was excused.
(c) state the name, ADDRESS, and telephone number of 50.4 Was any agreement alleged in the pleadings
each PERSON who is a witness to or has information terminated by mutual agreement, release, accord and
about each malfunction or defect; and satisfaction, or novation? If so, identify each agreement
(d) state the name, ADDRESS, and telephone number of terminated, the date of termination, and the basis of the
each PERSON who has custody of each defective part. termination.
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 unenforceable agreement and
defect in a vehicle contributed to the injuries sustained in the state why it is unenforceable.
INCIDENT? If so:
(a) identify the vehicle; 50.6 Is any agreement alleged in the pleadings
(b) identify each malfunction or defect; ambiguous? If so, identify each ambiguous agreement and
(c) state the name, ADDRESS, and telephone number of state why it is ambiguous.
each PERSON who is a witness to or has information
about each malfunction or defect; and 60.0 [Reserved]
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DISC-001 [Rev. January 1, 2007] FORM INTERROGATORIES—GENERAL
