Professional Documents
Culture Documents
Form Interrogatories
Form Interrogatories
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): Daniel E. Selarz, Esq. (287555)
CASE NUMBER:
FORM INTERROGATORIES—GENERAL
Asking Party: PLAINTIFF [Client's Name]
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).
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.
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.
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
17.0 Responses to Request for Admissions
DOCUMENT or thing.
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
INCIDENT? If so: (a) state the number of the request;
(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, (a) the year, make, model, and license number;
and telephone number of the PERSON who has each (b) the name, ADDRESS, and telephone number of the
DOCUMENT or thing. driver;
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
20.7 Was there a traffic signal facing you at the time of the name, ADDRESS, and telephone number of each
INCIDENT? If so, state: PERSON who has the DOCUMENT;
(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
and state why performance was excused.
(b) identify each malfunction or defect;
(c) state the name, ADDRESS, and telephone number of
50.4 Was any agreement alleged in the pleadings terminated
each PERSON who is a witness to or has information by mutual agreement, release, accord and satisfaction, or
about each malfunction or defect; and novation? If so, identify each agreement terminated, the date
(d) state the name, ADDRESS, and telephone number of of termination, and the basis of the termination.
each PERSON who has custody of each defective part.
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Daniel E. Selarz
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PROOF OF SERVICE
1 SERVICE LIST
3 [Attorney’s Name]
[Law Firm Name]
4 [Street Address]
[City, State & Zip Code]
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Tel: (xxx) xxx-xxxx / Fax: (xxx) xxx-xxxx
6 Email: [Email Address]
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S ELARZ L AW C ORP .
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11777 San Vicente Blvd., Suite 702
Los Angeles, California 90049
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PROOF OF SERVICE