California Approved Judicial Counsel Form Interrogatories General

1.0 Identity of Persons Answering These Interrogatories

 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

2.0 General Background Information – Individual

 2.1 State:³

(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.

 2.3 At the time of the INCIDENT, did you have a driver’s license? If so, state:⁴

(a) The state or other issuing entity;

(b) The license number and type;

(c) The date of issuance; and

(d) All restrictions.

 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:

(a) The state or other issuing entity;

(b) The license number and type;

(c) The date of issuance; and

(d) All restrictions.

 2.5 State

(a) Your present resident ADDRESS;

(b) Your residence ADDRESSES for the last five years; and

(c) The dates you lived at each ADDRESS.

 2.6 State

(a) The name, ADDRESS, and telephone number of your present employer or place of selfemployment; and

(b) The name, ADDRESS, dates of employment, job title, and nature of work for each employer or selfemployment you have had from five years before the INCIDENT until today.

 2.7 State:

(a) The name and ADDRESS of each school or other academic or vocational institution you have attended, beginning with high school;

(b) The dates you attended;

(c) The highest grade level you have completed; and

(d) The degrees received.

 2.8 Have you ever been convicted of a felony? If so, for each conviction state:⁵

(a) The city and state where you were convicted;

(b) The date of conviction;

(c) The offense; and

(d) The court and case number.

 2.9 Can you speak English with ease? If not, what language and dialect do you normally use?

 2.10 Can you read and write English with ease?⁶ If not, what language and dialect do you normally use?

 2.11 At the time of the INCIDENT, were you acting as an agent or employee for any PERSON? If so, state:⁷

(a) The name, ADDRESS, and telephone number of that PERSON; and

(b) A description of your duties.

 2.12 At the time of the INCIDENT, did you or any other 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:

(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.

 2.13 Within 24 hours before the INCIDENT, did you or any 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, ADDRESS, and telephone number;

(b) The nature or description of each substance;

(c) The quantity of each substance used or taken;

(d) The date and time of day when each substance was used or taken;

(e) The ADDRESS where each substance was used or taken;

(f) The name, ADDRESS, and telephone number of each person who was present when each substance was used or taken; and

(g) The name, ADDRESS, and telephone number of any HEALTH CARE PROVIDER that prescribed or furnished the substance and the condition for which it was prescribed or furnished.

3.0 General Background Information – Business Entity⁸

 3.1 Are you a corporation? If so, state:

(a) The name stated in the current articles of incorporation;

(b) All other names used by the corporation during the past ten years and the dates each was used;

(c) The date and place of incorporation;

(d) The ADDRESS of the principal place of business; and

(e) Whether you are qualified to do business in California.

 3.2 Are you a partnership? If so, state:

(a) The current partnership name;

(b) All other names used by the partnership during the past ten years and the dates each was used;

(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:

(a) The name stated in the current articles of organization;

(b) All other names used by the company during the past ten years and the dates 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.

 3.4 Are you a joint venture? If so, state:

(a) The current joint venture name;

(b) All other names used by the joint venture during the past ten 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.

 3.5 Are you an unincorporated association?⁹ If so, state:

(a) The current unincorporated association name;

(b) All other names used by the unincorporated association during the past ten 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 the past ten years? If so, for each fictitious name state:¹⁰

(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.

 3.7 Within the past five years has any public entity registered or licensed your businesses? If so, for each license or registration:

(a) Identify the license or registration;

(b) State the name of the public entity; and

(c) State the dates of issuance and expiration.

4.0 Insurance¹¹

 4.1 At the time of the INCIDENT, was there in effect any policy of insurance thorough which you were or might be insured in any manner (for example, primary, prorata, 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:

(a) The kind of coverage;

(b) The name and ADDRESS of the insurance company;

(c) The name, ADDRESS, and telephone number of each named insured;

(d) The policy number;

(e) The limits of coverage for each type of coverage contained in the policy;

(f) Whether any reservation of rights or controversy or coverage dispute exists between you and the insurance company; and

(g) The name, ADDRESS, and telephone number of the custodian of the policy.

 4.2 Are you selfinsured under any statute for the damages, claims, or actions that have arisen out of the INCIDENT? If so, specify the statute.

5.0 [Reserved]

6.0 Physical, Mental, or Emotional Injuries

 6.1 Do you attribute any physical, mental, or emotional injuries to the INCIDENT? (If your answer is “no,” do not answer 6.26.7).

 6.2 Identify each injury you attribute to the INCIDENT and the area of your body affected.

 6.3 Do you still have any complaints that you attribute to the INCIDENT? If so, for each complaint state:

(a) A description;

(b) Whether the complaint is subsiding, remaining the same, 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)¹² or treatment from a HEALTH CARE PROVIDER¹³ for any injury you attribute to the INCIDENT? If so, for each HEALTH CARE PROVIDER state:

(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

(d) The charges to date.

 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:¹⁴

(a) The name;

(b) The PERSON who prescribed or furnished it;

(c) The date prescribed or furnished;

(d) The dates you began and stopped taking it; and

(e) The cost to date.

 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:¹⁵

(a) The nature;

(b) The date;

(c) The cost; and

(d) The name, ADDRESS, and telephone number of each provider.

 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:

(a) The name and ADDRESS of each HEALTH CARE PROVIDER;

(b) The complaints for which the treatment was advised; and

(c) The nature, duration, and estimated cost of the treatment.

7.0 Property Damage

 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:

(a) Describe the property;

(b) Describe the nature and location of the damage to the property;

(c) State the amount of damage you are claiming for each item of property and how the amount was calculated; and

(d) If the property was sold, state the name, ADDRESS, and telephone number of the seller, the date of sale, and the sale price.

 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.

 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:

(c) The repair cost;

(d) The name, ADDRESS, and telephone number of the PERSON who repaired it; and

(e) The name, ADDRESS, and telephone number of the...