Document dDmGRrZwGVxxxMLoRVKnxkd0B

FILE NAME Kubota KUB DATE 2008 DOC KUB038 DOCUMENT DESCRIPTION Legal - Form Interrogatories - General ATTORNEY OR PARTY WITHOUT ATTORNEY Name State Bar number and address DISC JEJF REY EFFREY A. KAISER ESQ SBN 160594 T. SCOTT HAMES ESQ SBN 197574 LEVIN SIMES KAISER & GORNICK LLP 44 MONTGOMERY STREET 36TH FLOOR SAN FRANCISCO CALIFORNIA 94104 TELEPHONE NO FAX NO Optional 415 MAIL ADDRESS Optional 981-1270 ATTORNEY FOR Name RHODA EVANS AND BOBBY EVANS SUPERIOR COURT OF CALIFORNIA COUNTY OF SUPERIOR COURT OF CALIFORNIA STANLEY MOSK COURTHOUSE LOS ANGELES COUNTY OF L.A. SHORT TITLE OF CASE RHODA EVANS AND BOBBY EVANS vs. A. W. CHESTERTON COMPANY et al Asking Party FORM INTERROGATORIES PLAINTIFFS RHODA EVANS AND BOBBY EVANS Answering Party Set No KUBOTA CORPORATION ONE CASE NUMBER BC 418867 Sec 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 c Each answer must be as complete and straightforward as the information reasonably available to you including the information possessed by your attorneys or agents permits If an interrogatory cannot be answered completely answer it to the extent possible b For time limitations requirements for service on other parties and other details see Code of Civil Procedure sections 2030.010 2030.41a0nd the cases construing those sections c These form interrogatories do not change existing law relating to interrogatories nor do they affect an answering party's right to assert any privilege or make any objection Sec 2. Instructions to the Asking Party a These interrogatories are designed for optional use by parties in unlimited civil cases where the amount demanded exceeds 25,000 Separate interrogatories Form Interrogatories Civil Cases Economic Litigation form DISC which have no subparts are designed for use in limited civil cases where the amount demanded is 25,000 or less however those interrogatories may also be used in unlimited civil cases 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 c You may insert your own definition of INCIDENT in Section 4 but only where the action arises from a course of conduct or a series of events occurring over a period of time d The interrogatories in section 16.0 Defendant's Contentions 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 e Additional interrogatories may be attached Sec 3 Instructions to the Answering Party a An answer or other appropriate response must be given to each interrogatory checked by the asking party 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 information by asking other persons or organizations unless the information is equally available to the asking party 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 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 specifically assert the privilege of state the objection in your written response h Your answers to these interrogatories must be verified dated and signed You may wish to use the following form at the end of your answers I declare under penalty of perjury under the laws of the State of Califomia that the foregoing answers are true and correct DATE SIGNATURE Sec 4. Definitions Words in BOLDFACE CAPITALS in these interrogatories 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 2030.27f0or details this action or proceeding Page 1 8 of Form Approved for Optional Use Judicial Council of California FORM INTERROGATORIES __ Legal Code of Civil Procedure 2030.010-2030.410 2033.710 [_] 2 INCIDENT means insert your definition here or on a separate attached sheet labeled Sec 2 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 c PERSON includes a natural person firm association organization partnership business trust limited liability company corporation or public entity d DOCUMENT a means 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 e HEALTH CARE PROVIDER includes any PERSON referred to in Code of Civil Procedure section 667.7 f ADDRESS means the street address including the city state and zip code Sec 5. Interrogatories The following interrogatories have been approved by the Judicial Council under Code of Civil Procedure section 2033.710 CONTENTS 1.0 2.0 3.0 4.0 5.0 6.0 7.0 8.0 9.0 10.0 11.0 12.0 13.0 14.0 15.0 16.0 17.0 18.0 19.0 20.0 25.0 30.0 40.0 50.0 60.0 70.0 101.0 200.0 Identity of Persons Answering These Interrogatories General Background Information General Background Information Entity Insurance Reserved Physical Mental or Emotional Injuries Property Damage Loss of Income or Earning Capacity Other Damages Medical History Other Claims and Previous Claims Investigation - General Investigation - Surveillance Statutory or Regulatory Violations Denials and Special or Affirmative Defenses Defendant's Contentions Personal Injury Responses to Request for Admissions Reserved Reserved How the Incident Occurred Vehicle Reserved Reserved Reserved Contract Reserved Unlawful Detainer See separate form DISC Economic Litigation See separate form DISC Employment Law See separate form DISC Family Law See separate form 145 DISC 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 on 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 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 [|__| 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 |__} 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 residence ADDRESS b your residence ADDRESSES for the past 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 employment and b the name ADDRESS dates of employment job title and nature of work for each employer or employment you have had from five years before the INCIDENT until today [| 2.7 a State 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 each conviction state If so for 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 language and dialect do you normally use If not what [| 2.10 Can you read and write English with ease If not what language and dialect do you normally use DISC Rev. January 1 2008 FORM INTERROGATORIES Page 2 of B [___] 2.11 At the time of the INCIDENT were you acting as an agent or employee for any PERSON If so state a the name ADDRESS and telephone number of that PERSON and b 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 who prescribed or furnished the substance and the condition for which it was prescribed or furnished 3.0 General Background Information - Business Entity [|__|] 3.1 a b c d e Are you a corporation If so state the name stated in the current articles of incorporation all other names used by the corporation during the past 10 years and the dates each was used the date and place of incorporation the ADDRESS of the principal place of business and whether you are qualified to do business in California |] 3.2 a b c d e Are you a partnership If so state the current partnership name all other names used by the partnership during the past 10 years and the dates each was used whether you are a limited partnership and if so under the laws of what jurisdiction the name and ADDRESS of each general partner and the ADDRESS of the principal place of business (__] 3.3 a b c d _ e Are you a limited liability company If so state the name stated in the current articles of organization all other names used by the company during the past 10 years and the date each was used the date and place of filing of the articles of organization the ADDRESS of the principal place of business and whether you are qualified to do business in California DISC a the current joint venture name b all other names used by the joint venture during the 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 |__| 3.5 Are you an unincorporated association If so state a the current unincorporated association name b all names used by the unincorporated association 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 the past 10 years If so for each fictitious name 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 [_] 3.7 Within the past five years has any public entity regis- tered or licensed your business 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 Insurance [_] 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 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 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 con- tained 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 insured 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 interrogatories 6.2 through 6.7 6.2 Identify each injury you attribute to the INCIDENT and the area of your body affected DISC Rev. January 1 2008 FORM INTERROGATORIES GENERAL Page 3 of 8 |_| 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 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 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 a the name 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 [|__|] 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 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 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 DISC 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 e the name ADDRESS and telephone number of the PERSON who paid for the repair 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 [___] 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 |_| 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 8.5 State the date you returned to work at each place of employment following the INCIDENT |__} 8.6 State the dates you did not work and for which you lost income as a result of the INCIDENT ___| 8.7 State the total income you have lost to date as a result of the INCIDENT and how the amount was calculated [| 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 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 Rev. January 1 2008 FORM INTERROGATORIES Page 4 of 8 9.0 Other Damages [_ 9.1 Are there any other damages that you attribute to the INCIDENT 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 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 10.0 Medical History 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 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 PROVIDER whom you consulted or who examined or treated you 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 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 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 11.0 Other Claims and Previous Claims 4 11.1 filed Except for this action in the past 10 years have you an action or made a written claim or demand for compensation for your personal injuries If so for each action claim or demand state a the date time and place and location closest street ADDRESS or intersection of the INCIDENT 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 DISC 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 pending and f a description of the injury 11.2 In the past 10 years have you made a written claim o demand for workers compensation benefits 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 you 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 12.0 Investigation 12.1 State the name ADDRESS and telephone number o 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 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 12.2 Have YOU OR ANYONE ACTING ON YOUR BEHALF interviewed any individual INCIDENT If so for each individual state concerning _ the a the name ADDRESS and telephone number of the individual interviewed b the date of the interview and c the name ADDRESS and telephone number of the PERSON who conducted the interview 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 a the name ADDRESS and telephone number of the individual from whom the statement was obtained b the name ADDRESS and telephone number of the ; individual who obtained the statement 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 Rev. January 1 2008 FORM INTERROGATORIES Page 5 of Lo 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 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 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 2034.2102034.310 concerning the INCIDENT If so for each item state a the type i.e. diagram reproduction or model b the subject matter and c the name ADDRESS and telephone number of each PERSON who has it 12.6 Was a report made by any PERSON concerning the INCIDENT 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 12.7 Have YOU OR ANYONE ACTING ON YOUR BEHALF inspected the scene of the INCIDENT each inspection state If so for 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 2034.31a0nd b the date of the inspection 13.0 Investigation [I 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 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 DISC 13.2 Has a written report been prepared on the surveillance If so for each written report state a the title b the date c the name ADDRESS and telephone number of th individual who prepared the report and d the name ADDRESS and telephone number of eac PERSON who has the original or a copy 14.0 [Lt Statutory or Regulatory Violations 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 th violation was a legal proximate cause of the INCIDENT so identify the name ADDRESS and telephone number each PERSON and the statute ordinance or regulation tha was violated 15.0 14.2 Was any PERSON cited or charged with a violation o any statute ordinance or regulation as a result of thi INCIDENT If so for each PERSON state a the name ADDRESS and telephone number of th 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 administrativ agency of names the parties and case number Denials and Special or Affirmative Defenses 15.1 Identify each denial of a material allegation and eac special or affirmative defense in your pleadings and for each a state all facts upon which you base the denial or specia or affirmative defense b state the names ADDRESSES and telephone number of all PERSONS who have knowledge of those facts and c identify all DOCUMENTS and other tangible things tha support your denial or special or affirmative defense an state the name ADDRESS and telephone number o the PERSON who has each DOCUMENT 16.0 Defendant's Contentions Injury 16.1 Do you contend that any PERSON other than you o plaintiff contributed to the occurrence of the INCIDENT o the injuries or damages claimed by plaintiff If so for eac PERSON a state the name ADDRESS and telephone number o the PERSON b state all facts upon which you base your contention c state the names ADDRESSES and telephone number of all PERSONS who have knowledge of the facts and d identify all DOCUMENTS and other tangible things tha support your contention and state the name ADDRESS and telephone number of the PERSON who has eac DOCUMENT or thing 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 number of all PERSONS who have knowledge of the facts and c identify all DOCUMENTS and other tangible things tha support your contention and state the name ADDRESS and telephone number of the PERSON who has eac DOCUMENT or thing 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 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 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 |_ 1]6.4 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 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 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 16.5 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 a identify each cost (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 support your contention and state the name ADDRESS and telephone number of the PERSON who has each DOCUMENT or thing [| 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 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 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 16.7 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 a identify each item of property damage 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 support your contention and state the name ADDRESS and telephone number of the PERSON who has each DOCUMENT or thing . DISC 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 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 support your contention and state the name ADDRESS and telephone number of the PERSON who has each DOCUMENT or thing 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 bya plaintiff in this case If so for each plaintiff state 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 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 the name ADDRESS and telephone number of each HEALTH CARE PROVIDER b a description of each DOCUMENT and c the name ADDRESS and telephone number of the PERSON who has each DOCUMENT 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 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 18.0 Reserved 19.0 Reserved 20.0 How the Incident Occurred Vehicle [J 20.1 State the date time and place of the INCIDENT closest street ADDRESS or intersection C4 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 DISC IRev January 1 20081 FORM INTERROGATORIES GENERAL Page 7 of 8 DISC 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 |__] 20.3 State the ADDRESS and location where your trip began and the ADDRESS and location of your destination |_| 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 20.5 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 20.6 Did the INCIDENT occur at an intersection If so describe all traffic control devices signals or signs at the intersection [_} 20.7 Was a there traffic signal facing you at the time of the INCIDENT If so state a your location when you first saw it b the color 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 [__] 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 [_] 20.9 Do you have information that a malfunction or defect in a vehicle caused the INCIDENT 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 [| 20.10 Do you have information that any malfunction or defect in a vehicle contributed to the injuries sustained in the INCIDENT 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 ( __] 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 25.0 Reserved 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 name ADDRESS and telephone number of each PERSON agreeing to that provision and the date that part of the agreement was made 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 e) state each modification not in writing the date and the name ADDRESS and telephone number of each PERSON agreeing to the modification and the date the modification was made 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 [| 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 . [--] 50.3 Was performance of any agreement alleged in the pleadings excused If so identify each agreement excused and state why performance was excused [| 50.4 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 50.5 Is any agreement alleged in the pleadings unenforceable If so identify each unenforceable agreement and state why it is unenforceable | 50.6 Is any agreement alleged in the pleadings ambiguous If so identify each ambiguous agreement and state why it is ambiguous 60.0 Reserved DISC Rev. January 1 2008 FORM INTERROGATORIES Page 8 of 8