Fictional matter — created for portfolio demonstration. No real parties, courts, or facts.
discovery response defendant

San Bernardino County Superior Court

Reyes v. Pacific Western Logistics, Inc., et al. · No. CIVDS2401847 (FICTIONAL)

Defendants' Responses to Form Interrogatories — Set One

2025-02-11

[DEFENSE ATTORNEY NAME — STATE BAR NO. ######]
[DEFENSE FIRM NAME]
[ADDRESS LINE 1]
[CITY, STATE ZIP]
[PHONE | EMAIL]
Attorneys for Defendants PACIFIC WESTERN LOGISTICS, INC. and JOHN DOE

SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO

MARIA REYES,                                    Case No. CIVDS2401847 (FICTIONAL)
                        Plaintiff,
        v.                                      DEFENDANTS' RESPONSES TO PLAINTIFF'S
                                                FORM INTERROGATORIES — SET ONE
PACIFIC WESTERN LOGISTICS, INC.,
a California corporation; JOHN DOE;
and DOES 1 through 50,
                        Defendants.

DEFENDANTS’ RESPONSES TO PLAINTIFF’S FORM INTERROGATORIES — SET ONE

Propounding Party: Plaintiff MARIA REYES
Responding Party: Defendants PACIFIC WESTERN LOGISTICS, INC. and JOHN DOE
Set Number: One (1)

Defendants PACIFIC WESTERN LOGISTICS, INC. and JOHN DOE hereby respond to Plaintiff’s Form Interrogatories — Set One, as follows:

GENERAL OBJECTIONS:

Defendants assert the following General Objections to all Form Interrogatories:

  1. Defendants object to each interrogatory to the extent it seeks information protected by the attorney-client privilege, the attorney work product doctrine, or any other applicable privilege.
  2. Defendants object to each interrogatory to the extent it calls for expert opinion before the time for expert disclosure required by CCP § 2034.260.
  3. Defendants object to each interrogatory to the extent it is cumulative or duplicative of information requested in other discovery.
  4. These General Objections are incorporated by reference into each specific response below.

RESPONSE TO INTERROGATORY NO. 1.1 (Identity of Persons Answering)

Response: [CLAIMS REPRESENTATIVE NAME — REDACTED], Claims Representative at Pacific Western Logistics, Inc., assisted in the preparation of Defendant Pacific Western Logistics, Inc.’s responses. Defendant John Doe personally reviewed and verified his responses.

RESPONSE TO INTERROGATORY NOS. 2.1–2.2 (General Background — John Doe)

Response of JOHN DOE:

2.1: Defendant’s full legal name is [JOHN DOE — ACTUAL NAME REDACTED PER PROTECTIVE ORDER]. He has used no other legal names in the past five years. Date of birth: [REDACTED]. Place of birth: [REDACTED].

2.2: Defendant’s current principal residence is [ADDRESS — SUBJECT TO PROTECTIVE ORDER]. He has resided at this address since [DATE — REDACTED]. His prior residence for the relevant period was [ADDRESS — SUBJECT TO PROTECTIVE ORDER].

2.5: At the time of the INCIDENT, Defendant was employed full-time by Pacific Western Logistics, Inc. as a Class A CDL driver. He has been so employed since [DATE — REDACTED]. His work consists of operating commercial motor vehicles for the delivery of freight within California and interstate routes.

RESPONSE TO INTERROGATORY NOS. 3.1, 3.2, 3.6 (General Background — Pacific Western Logistics)

Response of PACIFIC WESTERN LOGISTICS, INC.:

3.1: Responding party is a corporation. It is incorporated in the State of California. Its current articles of incorporation state its name as Pacific Western Logistics, Inc. The corporation was incorporated on [DATE — REDACTED]. Its principal place of business is located at [ADDRESS — REDACTED]. It is qualified to do business in California.

3.2: Not applicable. Responding party is a corporation, not a partnership.

3.6: None of the listed events occurred in the past five years.

RESPONSE TO INTERROGATORY NO. 4.1 (Insurance)

Response: At the time of the INCIDENT, the following insurance policies were in force:

Primary Commercial Auto Liability Policy:

Excess/Umbrella Policy:

John Doe is an additional insured under the Pacific Western Logistics primary policy.

RESPONSE TO INTERROGATORY NO. 4.2 (Self-Insurance)

Response: Defendants are not self-insured under any statute.

RESPONSE TO INTERROGATORY NOS. 6.1–6.2 (Physical/Mental Disabilities — John Doe)

Response of JOHN DOE:

6.1: Defendant does not attribute any physical, mental, or emotional disability or condition to the INCIDENT.

6.2: Defendant had no pre-existing physical, mental, or emotional disabilities or conditions in the past ten years that are relevant to the operation of a motor vehicle or that he contends affected his actions at the time of the INCIDENT. Defendant was current on his DOT medical examination at the time of the INCIDENT.

RESPONSE TO INTERROGATORY NO. 9.1–9.2 (Other Damages)

Response: Defendants deny that they sustained any damages. This interrogatory, to the extent it is interpreted as asking what damages defendants claim, is inapplicable to these defendants.

RESPONSE TO INTERROGATORY NOS. 11.1–11.2 (Witnesses)

Response: Defendants are aware of the following persons with knowledge:

11.1: The following persons witnessed or have knowledge of the INCIDENT:

11.2: In addition to the above, the following persons have knowledge of facts relevant to this litigation:

RESPONSE TO INTERROGATORY NOS. 13.1–13.4 (Defendant’s Contentions — Personal Injury)

Response:

13.1: Defendants contend that Plaintiff’s own comparative fault in the manner in which she operated her vehicle was a contributing cause of the INCIDENT and of any claimed injuries. Defendants reserve the right to supplement this response as discovery proceeds.

13.2: Defendants do not presently contend that any person other than the parties to this action contributed to the cause of the INCIDENT, but reserve the right to designate nonparties for comparative fault under California Code of Civil Procedure § 877.6 as additional facts are developed.

13.3: Defendants contend that Plaintiff was comparatively negligent. Investigation and discovery are ongoing; the factual basis for this contention will be supplemented.

13.4: Defendants do not presently contend that Plaintiff assumed the risk of any of the claimed injuries.

RESPONSE TO INTERROGATORY NO. 20.1 (How the Incident Occurred)

Response: The INCIDENT occurred on November 4, 2023, at approximately 7:15 a.m., at the intersection of Milliken Avenue and the I-15 northbound off-ramp in Ontario, California.

RESPONSE TO INTERROGATORY NO. 20.2 (Vehicles Involved)

Response:

RESPONSE TO INTERROGATORY NO. 20.4 (Traffic Controls)

Response: Defendants are informed and believe that a traffic signal was present at the subject intersection controlling the flow of traffic. The precise signal phase applicable to each vehicle at the time of the INCIDENT is disputed and is the subject of ongoing investigation.

RESPONSE TO INTERROGATORY NO. 20.5 (Electronic Recording Devices)

Response: The VEHICLE was equipped with a [ELD VENDOR NAME — REDACTED] Electronic Logging Device (ELD) at the time of the INCIDENT. The ELD records driving time, on-duty/off-duty status, and location data. Data is retained for a minimum period required by 49 C.F.R. § 395.8. Defendants are in the process of determining the preservation status of data for the relevant period; counsel will supplement this response promptly upon confirmation.

RESPONSE TO INTERROGATORY NO. 20.8 (Intoxication)

Response: Defendants deny that John Doe or any other person operating a vehicle involved in the INCIDENT was under the influence of any alcoholic beverage or controlled substance at the time of the INCIDENT. John Doe voluntarily submitted to a post-accident substance screening; results were within legal limits.

VERIFICATION

I, JOHN DOE, declare under penalty of perjury under the laws of the State of California that the foregoing responses are true and correct to the best of my knowledge and belief.

Executed on February 11, 2025, at [CITY, CA].

JOHN DOE

I, [AUTHORIZED OFFICER — PACIFIC WESTERN LOGISTICS, INC. — NAME REDACTED], declare under penalty of perjury under the laws of the State of California that I am authorized to make this verification on behalf of Pacific Western Logistics, Inc., and that the foregoing responses on behalf of Pacific Western Logistics, Inc. are true and correct to the best of my knowledge and belief.

Executed on February 11, 2025, at [CITY, CA].

[AUTHORIZED OFFICER — NAME REDACTED]
[TITLE — REDACTED]
Pacific Western Logistics, Inc.

How this was made

Method

Used Claude to map each FROG paragraph number to the defendants' verified factual statement and insurance disclosure; objections drafted manually after reviewing which CCP § 2030.230 referral-to-documents grounds were supportable; paralegal reviewed each response for internal consistency with the Answer's affirmative defenses.

Human judgment points

  • Decided to respond to FROG 13.2 (comparative fault contention) with a non-evasive partial admission that the light phase was disputed rather than an outright denial — a strategic call requiring judgment about the evidentiary record available at this stage
  • Chose to respond to FROG 4.1 (insurance) with a complete disclosure rather than a partial objection, because California law is unambiguous that insurance policy information is discoverable under CCP § 2017.210 and stonewall-style objections would invite sanctions
  • Determined that FROG 20.5 (electronic recording devices) required a specific response identifying the ELD vendor rather than a qualified 'object and respond' because evasion on device identification is inconsistent with defendants' stated position that ELD data exists but is proprietary

Time

~3 hours AI-augmented vs ~9 hours traditional response drafting