NO. 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.)

NO. 2.1. State: (a) your name; (b) every name you have used in the past; and (c) The dates you used each name.

NO. 2.2: State the date and place of your birth.

NO. 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;

NO. 2.4: At the time of the INCIDENT, did you have any other permit or license for the operation of a motor vehicle?

Yes

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.

No

NO. 2.5: State: (a) your present residence ADDRESS; (b) your residence ADDRESSES for the past five years; and (c) the dates you lived at each ADDRESS.

NO. 2.6: State: the name, ADDRESS, and telephone number of your present employer or place of self-employment; and 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.

NO. 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.

NO. 2.8: Have you ever been convicted of a felony?

Yes

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.

No

NO. 2.9: Can you speak English with ease?

Yes

No

If not, what language and dialect do you normally use?

NO. 2.10: Can you read and write English with ease?

Yes

No

If not, what language and dialect do you normally use?

At the time of the INCIDENT were you acting as an agent or employee for any PERSON?

Yes

If so, state: the name, ADDRESS, and telephone number of that person; and a description of your duties.

No

NO. 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?

Yes

If so, for each person state: the name, ADDRESS, and telephone number; the nature of the disability or condition; and the manner in which the disability or condition contributed to the occurrence of the INCDIENT.

No

NO. 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: alcohol beverage, marijuana, or other drug or medication of any kind (prescription or not)?

Yes

If so, for each person state: the name, ADDRESS, and telephone number; the nature or description of each substance; the quantity of each substance used or taken; the date and time of day when each substance was used or taken; the ADDRESS where each substance was used or taken; the name, ADDRESS, and telephone number of each person who was present when each substance was used or taken; and 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.

No

NO. 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?

Yes

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.

No

NO. 4.2: Are you self-insured under any statute for the damages, claims, or actions that have arisen out of the INCIDENT?

Yes

If so, specify the statute.

No

NO. 6.1: Do you attribute any physical, mental, or emotional injuries to the INCIDENT?

Yes

No

NO. 6.2: Identify each injury you attribute to the INCIDENT and the area of your body affected.

Do you attribute any physical, mental, or emotional injuries to the INCIDENT

Yes

If so, for each complaint state: (a) a description; (b) whether the complaint is subsiding, remaining the same or becoming worse; and (c) the frequency and duration.

No

NO. 6.4: Did you receive any consultation or examination (except from expert witnesses covered by Code of Civil Procedure 2034.210-2034.310) or treatment from a HEALTH CARE PROVIDER for any injury you attribute to the INCIDENT?

Yes

If so, for each HEALTH CARE PROVIDER state: the name, ADDRESS, and telephone number; the type of consultation, examination, or treatment provided; the dates you received consultation, examination, or treatment; and the charges to date.

No

NO. 6.5: Have you taken any medication, prescribed or not, as a result of the injuries that you attribute to the INCIDENT?

Yes

If so, for each medication state: the name; the PERSON who prescribed or furnished it; the date it was prescribed or furnished; the dates you began and stopped taking it; and the cost to date.

No

NO. 6.6: Are there any other medical services necessitated by the injuries that you attribute to the INCIDENT that were not previously listed?

Yes

What are they (for example, ambulance, nursing, prosthetics)?

No

Has any HEATH CARE PROVIDER advised that you may require future or additional treatment for any injuries that you attribute to the INCIDENT?

Yes

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.

No

NO. 7.1: Do you attribute any loss of or damage to a vehicle or other property to the INCIDENT?

Yes

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.

No

NO. 7.2: Has a written estimate or evaluation been made for any item of property referred to in your answer to the preceding interrogatory?

Yes

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.

No

NO. 7.3: Has any item of property referred to in your answer to interrogatory 7.1 been repaired?

Yes

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; (e) the name, ADDRESS, and telephone number of the PERSON who paid for the repair.

No

NO. 8.1: Do you attribute any loss of income or earning capacity to the INCIDENT?

Yes

No

NO. 8.2: State: the nature of your work; your job title at the time of the INCIDENT; the date your employment began.

NO. 8.3: State the last date before the INCIDENT that you worked for compensation.

NO. 8.4: State your monthly income at the time of the INCIDENT and how the amount was calculated.

NO. 8.5: State the date you returned to work at each place of employment following the INCIDENT.

NO. 8.6: State the dates you did not work and for which you lost income as a result of the INCIDENT.

NO. 8.7: State the total income you have lost to date as a result of the INCIDENT and how the amount was calculated.

NO. 8.8: Will you lose income in the future as a result of the INCIDENT?

Yes

If so, state: (a) the facts upon which you base this contention; (b) the estimate of the amount; (c) an estimate of how long you will be unable to work; (d) how the claim for future income is calculated.

No

NO. 9.1: Are there any other damages that you attribute to the INCIDENT?

Yes

If so, for each item of damage state: (a) the nature; (b) the date it occurred; (c) the amount; and (d) the name, ADDRESS, and telephone number of each PERSON to whom an obligation was incurred.

No

NO. 9.2: Do any DOCUMENTS support the existence or amount of any item of damages claimed in interrogatory 9.1?

Yes

If so, describe each document and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT.

No

NO. 10.1: At any time before the INCIDENT did you have any complaints or injuries that involved the same part of your body claimed to have been injured in the INCIDENT?

Yes

If so, for each state: (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 HEALTH CARE PROIDER whom you consulted or who examined or treated you.

No

NO. 10.2: List all physical, mental, and emotional disabilities you had immediately before the INCIDENT.

NO. 10.3: At any time after the INCIDENT, did you sustain injuries of the kind for which you are now claiming damages?

Yes

If so, for each incident giving rise to any injury state: (a) the date and the place it occurred; (b) the name, ADDRESS, and telephone number of any other PERSON involved; (c) the nature of any injuries you sustained; (d) the name, ADDRESS, and telephone number of each HEALTH CARE PROVIDER who you consulted or who examined or treated you; and (e) the nature of the treatment and its duration.

No

NO. 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?

Yes

If so, for each action, claim or demand state: (a) the date, time and place and location (closest street ADDRESS or intersection) of the INCDENT giving rise to the action, claim, or demand; (b) the name, ADDRESS, and telephone number of each PERSON against whom the claim or demand was made or the action filed; (c) the court, names of the parties the 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 pending; and (f) a description of the injury.

No

NO. 11.2: In the past 10 years have you made a written claim or demand for workers’ compensation benefits?

Yes

If so, for each claim or demand state: (a) the date, time, and place of the INCIDENT giving rise to 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; (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.

No

NO. 12.1: State the name, ADDRESS and telephone number of each individual: (a) who witnessed the INCIDENT or the events occurring 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; (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)

NO. 12.2: Have YOU OR ANYONE ACTING ON YOUR BEHALF interviewed any individual concerning the INCIDENT?

Yes

If so, for each individual state: the name, ADDRESS, and telephone number of the interviewed; the date of the interview; and the name, ADDRESS, and telephone number of the PERSON who conducted the interview.

No

NO. 12.3: Have YOU OR ANYONE ACTING ON YOUR BEHALF obtained a written or recorded statement from any individual concerning the INCIDENT?

Yes

If so, for each statement state: the name, ADDRESS, and telephone number of the individual from whom the statement was obtained; the name, ADDRESS, and telephone number of the individual who obtained the statement; the date the statement was obtained; and the name, ADDRESS, and telephone number of each PERSON who has the original statement or a copy.

No

NO. 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?

Yes

If so, state: (a) the number of photographs or feet of film or videotape; (b) the places, objects, or persons photographed, filmed, or videotaped; (c) the date the photographs, films, or videotapes were taken; (d) the name, ADDRESS, and telephone number of the individual taking the photographs, films, or videotapes; and (e) the name, ADDRESS, and telephone number of each PERSON who has the original or a copy of the photographs, films, or videotapes.

No

NO. 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?

Yes

If so, for each item state: (a) the name, ADDRESS, and telephone number of the PERSON; (b) the subject matter; and (c) the name, ADDRESS, and telephone number of each PERSON who has it.

No

NO. 12.6: Was a report made by any PERSON concerning the INCIDENT?

Yes

If so, state: (a) the name, title, identification number, and employer of the PERSON who made the report; (b) the date and type of report made; (c) the name, ADDRESS, and telephone number of the PERSON for whom the report was made; and (d) the name, ADDRESS, and telephone number of each PERSON who has the original or a copy of the report.

No

NO. 12.7: Have YOU OR ANYONE ACTING ON YOUR BEHALF inspected the scene of the INCIDENT?

Yes

If so, for each inspection state: (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 sections 2034.210–2034.310); and (b) the date of the inspection.

No

NO. 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?

Yes

If so, for each surveillance state: (a) the name, ADDRESS, and telephone number of the individual or party; (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.

No

NO. 13.2: Has a written report been prepared on the surveillance?

Yes

If so, for each written report state: (a) the title; (b) the date; (c) the name, ADDRESS, and telephone number of the individual who prepared the report; and (d) the name, ADDRESS, and telephone number of each PERSON who has the original or a copy.

No

NO. 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?

Yes

If so, identify the name, ADDRESS, and telephone number of each PERSON and the statute, ordinance, or regulation that was violated.

No

NO. 14.2: Was any PERSON cited or charged with a violation of any statute, ordinance, or regulation as a result of this INCIDENT?

Yes

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 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.

No

NO. 15.1: Identify each denial of a material allegation and each special or affirmative defense in your pleadings and for each: (a) state all facts upon which you base the denial or special 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 support your denial or special or affirmative defense, and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT.

NO. 20.1: State the date, time, and place of the INCIDENT (closest street ADDRESS or intersection).

NO. 20.2: For each vehicle involved in the INCIDENT, state: (a) the year, make, model, and license number; (b) the name, ADDRESS, and telephone number of the driver; (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; (e) the name, ADDRESS, and telephone number of each lessee; (f) the name, ADDRESS, and telephone number of each owner other than the registered owner or lien holder; and (g) the name of each owner who gave permission or consent to the driver to operate the vehicle.

NO. 20.3: State the ADDRESS and location where your trip began and the ADDRESS and location of your destination.

NO. 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.

NO. 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.

NO. 20.6: Did the INCIDENT occur at an intersection?

Yes

If so, describe all traffic control devices, signals, or signs at the intersection.

No

NO. 20.7: Was there a traffic signal facing you at the time of the INCIDENT?

Yes

If so, state: (a) your location when you first saw it; (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.

No

NO. 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.

NO. 20.9: Do you have information that a malfunction or defect in a vehicle caused the INCIDENT?

Yes

If so: (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; and (d) state the name, ADDRESS, and telephone number of each PERSON who has custody of each defective part.

No

NO. 20.10: Do you have information that any malfunction or defect in a vehicle contributed to the injuries sustained in the INCIDENT?

Yes

If so: (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; and (d) state the name, ADDRESS, and telephone number of each PERSON who has custody of each defective part.

No

NO. 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.

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