[ATTORNEY NAME — STATE BAR NO. ######]
[FIRM NAME]
[ADDRESS LINE 1]
[CITY, STATE ZIP]
[PHONE | EMAIL]
Attorneys for Plaintiff MARIA REYES
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO
MARIA REYES, Case No. CIVDS2401847 (FICTIONAL)
Plaintiff,
v. PLAINTIFF'S FORM INTERROGATORIES
TO DEFENDANTS — SET ONE
PACIFIC WESTERN LOGISTICS, INC., (Judicial Council Form DISC-001)
a California corporation; JOHN DOE;
and DOES 1 through 50,
Defendants.
PLAINTIFF’S FORM INTERROGATORIES TO DEFENDANTS — SET ONE
Propounding Party: Plaintiff MARIA REYES
Responding Party: Defendants PACIFIC WESTERN LOGISTICS, INC. and JOHN DOE
Set Number: One (1)
PLAINTIFF hereby propounds the following Form Interrogatories upon Defendants pursuant to California Code of Civil Procedure § 2030.010 et seq. and Judicial Council Form DISC-001. Responses are required within thirty (30) days of service pursuant to CCP § 2030.260.
INSTRUCTIONS: These form interrogatories are taken from the official Judicial Council Form DISC-001. Check marks indicate the categories selected. Each responding party must answer each interrogatory separately and fully. Under CCP § 2030.220, each answer must be as complete and straightforward as the information reasonably available to the responding party, including information possessed by the responding party’s agents, representatives, and, unless privileged, attorneys.
SECTION 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.)
SECTION 2.0 — GENERAL BACKGROUND INFORMATION — INDIVIDUAL
2.1 State:
(a) your name;
(b) every name you have used in the past five years and the dates you used each name;
(c) your date and place of birth.
2.2 State the ADDRESS of your principal residence and all other residences for the past three years.
2.5 State:
(a) the name and ADDRESS of your present employer or principal business;
(b) the dates of that employment or business;
(c) the nature of the work you perform.
SECTION 3.0 — GENERAL BACKGROUND INFORMATION — BUSINESS ENTITY
(Applicable to Defendant PACIFIC WESTERN LOGISTICS, INC. only)
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 10 years and the dates each was used;
(c) the date and place of incorporation;
(d) the ADDRESS of the principal place of business;
(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 10 years; (c) whether it is a limited or general partnership; (d) the ADDRESS of the principal place of business.
3.6 Within the past five years, have any of the following occurred? (a) a sale of any substantial portion of the business or its assets; (b) a change in the corporate name; (c) a merger; (d) a dissolution; (e) a declaration of bankruptcy; (f) an assignment for the benefit of creditors; (g) a receivership; (h) a court-approved reorganization; (i) a change in ownership of more than 25 percent of the outstanding shares of stock.
SECTION 4.0 — INSURANCE
4.1 At the time of the INCIDENT, was there in force 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? 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.
4.2 Are you self-insured under any statute for the damages, claims, or actions that have arisen out of the INCIDENT? If so, specify the statute.
SECTION 6.0 — PHYSICAL, MENTAL, OR EMOTIONAL DISABILITIES
6.1 Do you attribute any physical, mental, or emotional disability or condition to the INCIDENT? If so, for each disability or condition state: (a) a description; (b) the date it began; (c) whether it has ceased; (d) all current symptoms.
6.2 Within the PAST 10 YEARS, have you had any physical, mental, or emotional disability or condition? If so, for each state: (a) a description of the disability or condition; (b) the date it began; (c) the date it ceased, if applicable.
(Note: Interrogatory 6.0 directed to Defendant JOHN DOE individually.)
SECTION 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;
(d) if the property was sold, state the name, ADDRESS, and telephone number of the seller, the date of sale, and the sale price.
SECTION 8.0 — LOSS OF INCOME OR EARNING CAPACITY
8.1 Do you attribute any loss of income or earning capacity to the INCIDENT? If so, state:
(a) the nature of your work before the INCIDENT;
(b) your monthly income at the time of the INCIDENT and how it was calculated;
(c) the date your income was first affected by the INCIDENT;
(d) how your income was affected (e.g., lost time from work, loss of business);
(e) if your income was cut off, the date it was cut off and the reasons;
(f) the total income you have lost to date and how that amount was calculated;
(g) will you lose income in the future as a result of the INCIDENT? If so, set forth the facts on which you base this contention.
(Note: Interrogatory 8.0 directed to Plaintiff. Propounded here to defendants for their contentions as to plaintiff’s income losses.)
SECTION 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 9.1? If so, describe each document and state the name, ADDRESS, and telephone number of the PERSON who has each document.
SECTION 11.0 — WITNESSES
11.1 Do you know the name, ADDRESS, or telephone number of any person (other than yourself) who witnessed the INCIDENT or the events occurring immediately before or after the INCIDENT? If so, for each person state: (a) the name, ADDRESS, and telephone number; (b) what the person witnessed.
11.2 Do you know the name, ADDRESS, or telephone number of any person who has knowledge of any fact that might affect the outcome of this lawsuit? If so, for each person state: (a) the name, ADDRESS, and telephone number; (b) the subject matter of the knowledge.
SECTION 12.0 — SETTLEMENT DEMANDS AND AGREEMENTS
12.1 Have you made any oral or written settlement agreement with any opposing party or any third party in connection with this lawsuit? If so, state the terms of the agreement and the parties to the agreement.
12.4 Has any insurance company paid, or agreed to pay, any amount in settlement or as payment of a claim arising out of the INCIDENT? If so, state: (a) the name of the insurance company making payment; (b) the amount paid or agreed to be paid; (c) the name and address of the person to whom payment was made.
SECTION 13.0 — DEFENDANT’S CONTENTIONS — PERSONAL INJURY
13.1 Identify each act or omission on the part of any party to this action that you contend was a cause of any injury or damage claimed by plaintiff.
13.2 Do you contend that any person, other than you or plaintiff, contributed to the cause of the INCIDENT or plaintiff’s claimed injuries? If so, state:
(a) the name, ADDRESS, and telephone number of each such person;
(b) the nature of each person’s act or omission; and
(c) the percentage of fault you attribute to each person.
13.3 Do you contend that plaintiff was contributorily or comparatively negligent? If so, describe what plaintiff did or failed to do.
13.4 Do you contend that plaintiff assumed the risk of any of the alleged injuries or damages? If so, state: (a) the risk assumed; (b) how plaintiff assumed the risk; (c) the facts on which you base your contention.
SECTION 14.0 — DENIALS AND SPECIAL OR AFFIRMATIVE DEFENSES
14.1 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; (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.
SECTION 15.0 — DENIALS AND CONTENTIONS — PROPERTY DAMAGE
15.1 Do you contend that any of the property damage claimed by plaintiff in this action was not caused by the INCIDENT? If so, identify each item of claimed damage that you contend was not caused by the INCIDENT and state all facts on which you base your contention.
SECTION 16.0 — DEFENDANT’S CONTENTIONS — BODILY INJURY
16.1 Do you contend that any of the medical treatment received by plaintiff was not caused by the INCIDENT? If so, state: (a) the medical treatment; (b) the date of the treatment; (c) the name, ADDRESS, and telephone number of the provider; (d) all facts on which you base your contention.
16.2 Do you contend that any aspect of the injury claimed by plaintiff existed prior to the INCIDENT? If so, describe each injury and state all facts on which you base your contention.
16.3 Do you contend that any of plaintiff’s injuries were caused by a subsequent incident or condition unrelated to this lawsuit? If so, describe each injury and the subsequent incident or condition.
SECTION 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; (d) identify all DOCUMENTS supporting your response.
SECTION 20.0 — HOW THE INCIDENT OCCURRED
20.1 State the date, time, and place of the INCIDENT (closest street ADDRESS or intersection).
20.2 For each vehicle involved in the INCIDENT, state: (a) the year, make, model, and license plate number; (b) the name, ADDRESS, and telephone number of the owner; (c) the name, ADDRESS, and telephone number of the driver; (d) the name of each occupant.
20.4 Did the INCIDENT occur at an intersection? If so, describe all traffic controls present.
20.5 Was any vehicle involved in the INCIDENT equipped with any mechanical, electronic, or other device designed to record its speed, direction, or other data? If so, state the name and nature of each device and describe all data recorded by each device.
20.6 Were you or any person involved in the INCIDENT cited or convicted of any traffic violation? If so, for each citation or conviction state: (a) the name of the person cited or convicted; (b) the nature of the violation; (c) the date; (d) the court, its location, and the case number.
20.8 At the time of the INCIDENT, were you or any other person involved in the INCIDENT under the influence of any alcoholic beverage or drug? If so, identify each such person and the alcoholic beverage or drug consumed.
Date: January 10, 2025
[ATTORNEY NAME — STATE BAR NO. ######]
[FIRM NAME]
Attorneys for Plaintiff MARIA REYES