DISC-001

ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):

TELEPHONE NO.:

FAX NO. (Optional):

E-MAIL ADDRESS (Optional):
ATTORNEY FOR (Name):

SUPERIOR COURT OF CALIFORNIA, COUNTY OF

SHORT TITLE OF CASE:

FORM INTERROGATORIES—GENERAL CASE NUMBER:

Asking Party:
Answering Party:
Set No.:

Sec. 1. Instructions to All Parties (c) Each answer must be as complete and straightforward as
(a) Interrogatories are written questions prepared by a party to an the information reasonably available to you, including the
action that are sent to any other party in the action to be information possessed by your attorneys or agents, permits.
answered under oath. The interrogatories below are form If an interrogatory cannot be answered completely, answer it
interrogatories approved for use in civil cases. to the extent possible.
(b) For time limitations, requirements for service on other parties, (d) If you do not have enough personal knowledge to fully
and other details, see Code of Civil Procedure sections answer an interrogatory, say so, but make a reasonable and
2030.010–2030.410 and the cases construing those sections. good faith effort to get the information by asking other
(c) These form interrogatories do not change existing law persons or organizations, unless the information is equally
relating to interrogatories nor do they affect an answering available to the asking party.
party’s right to assert any privilege or make any objection. (e) Whenever an interrogatory may be answered by referring to
Sec. 2. Instructions to the Asking Party a document, the document may be attached as an exhibit to
(a) These interrogatories are designed for optional use by parties the response and referred to in the response. If the
in unlimited civil cases where the amount demanded exceeds document has more than one page, refer to the page and
$25,000. Separate interrogatories, Form Interrogatories— section where the answer to the interrogatory can be found.
Limited Civil Cases (Economic Litigation) (form DISC-004), (f) Whenever an address and telephone number for the same
which have no subparts, are designed for use in limited civil person are requested in more than one interrogatory, you
cases where the amount demanded is $25,000 or less; are required to furnish them in answering only the first
however, those interrogatories may also be used in unlimited interrogatory asking for that information.
civil cases.
(b) Check the box next to each interrogatory that you want the (g) If you are asserting a privilege or making an objection to an
answering party to answer. Use care in choosing those interrogatory, you must specifically assert the privilege or
interrogatories that are applicable to the case. state the objection in your written response.
(c) You may insert your own definition of INCIDENT in Section 4, (h) Your answers to these interrogatories must be verified,
but only where the action arises from a course of conduct or a dated, and signed. You may wish to use the following form
series of events occurring over a period of time. at the end of your answers:
(d) The interrogatories in section 16.0, Defendant’s Contentions–
I declare under penalty of perjury under the laws of the State of
Personal Injury, should not be used until the defendant has
California that the foregoing answers are true and correct.
had a reasonable opportunity to conduct an investigation or
discovery of plaintiff’s injuries and damages.
(e) Additional interrogatories may be attached. (Date) (SIGNATURE)

Sec. 3. Instructions to the Answering Party Sec. 4. Definitions

(a) An answer or other appropriate response must be given to Words in BOLDFACE CAPITALS in these interrogatories are
each interrogatory checked by the asking party. defined as follows:
(b) As a general rule, within 30 days after you are served with (a) (Check one of the following):
these interrogatories, you must serve your responses on the
(1) INCIDENT includes the circumstances and
asking party and serve copies of your responses on all other
events surrounding the alleged accident, injury,
parties to the action who have appeared. See Code of Civil
or other occurrence or breach of contract giving
Procedure sections 2030.260–2030.270 for details.
rise to this action or proceeding.
Page 1 of 8
Form Approved for Optional Use Code of Civil Procedure, §§
Judicial Council of California FORM INTERROGATORIES—GENERAL 2030.010-2030.410, 2033.710
DISC-001 [Rev. January 1, 2008] www.courts.ca.gov
 DISC-001
(2) INCIDENT means (insert your definition here or on a 1.0 Identity of Persons Answering These Interrogatories
separate, attached sheet labeled “Sec. 4(a)(2)”): 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.)
2.0 General Background Information individual—
(b) YOU OR ANYONE ACTING ON YOUR BEHALF includes 2.1 State:
you, your agents, your employees, your insurance (a) your name;
companies, their agents, their employees, your attorneys, (b) every name you have used in the past; and
your accountants, your investigators, and anyone else acting
(c) the dates you used each name.
on your behalf.
2.2 State the date and place of your birth.
(c) PERSON includes a natural person, firm, association,
organization, partnership, business, trust, limited liability 2.3 At the time of the INCIDENT, did you have a driver's
company, corporation, or public entity. license? If so state:
(d) DOCUMENT means a writing, as defined in Evidence Code (a) the state or other issuing entity;
section 250, and includes the original or a copy of (b) the license number and type;
handwriting, typewriting, printing, photostats, photographs, (c) the date of issuance; and
electronically stored information, and every other means of (d) all restrictions.
recording upon any tangible thing and form of communicating
2.4 At the time of the INCIDENT, did you have any other
or representation, including letters, words, pictures, sounds,
permit or license for the operation of a motor vehicle? If so,
or symbols, or combinations of them.
state:
(e) HEALTH CARE PROVIDER includes any PERSON referred
to in Code of Civil Procedure section 667.7(e)(3). (a) the state or other issuing entity;
(f) ADDRESS means the street address, including the city, (b) the license number and type;
state, and zip code. (c) the date of issuance; and
(d) all restrictions.
Sec. 5. Interrogatories
2.5 State:
The following interrogatories have been approved by the Judicial (a) your present residence ADDRESS;
Council under Code of Civil Procedure section 2033.710:
(b) your residence ADDRESSES for the past five years;
CONTENTS and

1.0 Identity of Persons Answering These Interrogatories (c) the dates you lived at each ADDRESS.
2.0 General Background Information—Individual 2.6 State:
3.0 General Background Information—Business Entity (a) the name, ADDRESS, and telephone number of your
4.0 Insurance present employer or place of self-employment; and
5.0 [Reserved]
6.0 Physical, Mental, or Emotional Injuries (b) the name, ADDRESS, dates of employment, job title,
7.0 Property Damage and nature of work for each employer or self-
8.0 Loss of Income or Earning Capacity employment you have had from five years before the
9.0 Other Damages INCIDENT until today.
10.0 Medical History 2.7 State:
11.0 Other Claims and Previous Claims
(a) the name and ADDRESS of each school or other
12.0 Investigation—General
academic or vocational institution you have attended,
13.0 Investigation—Surveillance
14.0 Statutory or Regulatory Violations beginning with high school;
15.0 Denials and Special or Affirmative Defenses (b) the dates you attended;
16.0 Defendant’s Contentions Personal Injury (c) the highest grade level you have completed; and
17.0 Responses to Request for Admissions (d) the degrees received.
18.0 [Reserved]
19.0 [Reserved] 2.8 Have you ever been convicted of a felony? If so, for
20.0 How the Incident Occurred—Motor Vehicle each conviction state:
25.0 [Reserved] (a) the city and state where you were convicted;
30.0 [Reserved] (b) the date of conviction;
40.0 [Reserved] (c) the offense; and
50.0 Contract
60.0 [Reserved] (d) the court and case number.
70.0 Unlawful Detainer [See separate form DISC-003] 2.9 Can you speak English with ease? If not, what
101.0 Economic Litigation [See separate form DISC-004] language and dialect do you normally use?
200.0 Employment Law [See separate form DISC-002] Family 2.10 Can you read and write English with ease? If not,
Law [See separate form FL-145] what language and dialect do you normally use?

DISC-001 [Rev. January 1, 2008] Page 2 of 8

FORM INTERROGATORIES—GENERAL
 DISC-001
2.11 At the time of the INCIDENT were you acting as an 3.4 Are you a joint venture? If so, state:
agent or employee for any PERSON? If so, state: (a) the current joint venture name;
(a) the name, ADDRESS, and telephone number of that (b) all other names used by the joint venture during the
PERSON: and past 10 years and the dates each was used;
(b) a description of your duties. (c) the name and ADDRESS of each joint venturer; and
2.12 At the time of the INCIDENT did you or any other (d) the ADDRESS of the principal place of business.
person have any physical, emotional, or mental disability or
condition that may have contributed to the occurrence of the 3.5 Are you an unincorporated association? If so, state:
INCIDENT? If so, for each person state: (a) the current unincorporated association name;
(a) the name, ADDRESS, and telephone number; (b) all other names used by the unincorporated
(b) the nature of the disability or condition; and association during the past 10 years and the dates
(c) the manner in which the disability or condition each was used; and
contributed to the occurrence of the INCIDENT. (c) the ADDRESS of the principal place of business.
2.13 Within 24 hours before the INCIDENT did you or any 3.6 Have you done business under a fictitious name during
person involved in the INCIDENT use or take any of the the past 10 years? If so, for each fictitious name state:
following substances: alcoholic beverage, marijuana, or
other drug or medication of any kind (prescription or not)? If (a) the name;
so, for each person state: (b) the dates each was used;
(a) the name, ADDRESS, and telephone number; (c) the state and county of each fictitious name filing; and
(b) the nature or description of each substance; (d) the ADDRESS of the principal place of business.
(c) the quantity of each substance used or taken; 3.7 Within the past five years has any public entity
(d) the date and time of day when each substance was registered or licensed your business? If so, for each license
used or taken; or registration:
(e) the ADDRESS where each substance was used or (a) identify the license or registration;
taken;
(b) state the name of the public entity; and
(f) the name, ADDRESS, and telephone number of each
person who was present when each substance was (c) state the dates of issuance and expiration.
used or taken; and 4.0 Insurance
(g) the name, ADDRESS, and telephone number of any 4.1 At the time of the INCIDENT, was there in effect any
HEALTH CARE PROVIDER who prescribed or policy of insurance through which you were or might be
furnished the substance and the condition for which it insured in any manner (for example, primary, pro-rata, or
was prescribed or furnished. excess liability coverage or medical expense coverage) for
3.0 General Background Information—Business Entity the damages, claims, or actions that have arisen out of the
INCIDENT? If so, for each policy state:
3.1 Are you a corporation? If so, state:
(a) the name stated in the current articles of incorporation; (a) the kind of coverage;
(b) all other names used by the corporation during the past (b) the name and ADDRESS of the insurance company;
10 years and the dates each was used; (c) the name, ADDRESS, and telephone number of each
(c) the date and place of incorporation; named insured;
(d) the ADDRESS of the principal place of business; and (d) the policy number;
(e) whether you are qualified to do business in California.
(e) the limits of coverage for each type of coverage
3.2 Are you a partnership? If so, state: contained in the policy;
(a) the current partnership name;
(f) whether any reservation of rights or controversy or
(b) all other names used by the partnership during the past
coverage dispute exists between you and the
10 years and the dates each was used;
insurance company; and
(c) whether you are a limited partnership and, if so, under (g) the name, ADDRESS, and telephone number of the
the laws of what jurisdiction; custodian of the policy.
(d) the name and ADDRESS of each general partner; and 4.2 Are you self-insured under any statute for the
(e) the ADDRESS of the principal place of business. damages, claims, or actions that have arisen out of the
3.3 Are you a limited liability company? If so, state: INCIDENT? If so, specify the statute.
(a) the name stated in the current articles of organization; 5.0 [Reserved]
(b) all other names used by the company during the past 6.0 Physical, Mental, or Emotional Injuries
10 years and the date each was used;
6.1 Do you attribute any physical, mental, or emotional
(c) the date and place of filing of the articles of injuries to the INCIDENT? (If your answer is “no,” do not
organization; answer interrogatories 6.2 through 6.7).
(d) the ADDRESS of the principal place of business; and 6.2 Identify each injury you attribute to the INCIDENT and
(e) whether you are qualified to do business in California. the area of your body affected.
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 DISC-001

6.3 Do you still have any complaints that you attribute to the (c) state the amount of damage you are claiming for
INCIDENT? If so, for each complaint state: each item of property and how the amount was
(a) a description; calculated; and
(b) whether the complaint is subsiding, remaining the (d) if the property was sold, state the name, ADDRESS,
same, or becoming worse; and and telephone number of the seller, the date of sale,
(c) the frequency and duration. and the sale price.

6.4 Did you receive any consultation or examination (except 7.2 Has a written estimate or evaluation been made for any
from expert witnesses covered by Code of Civil Procedure item of property referred to in your answer to the preceding
sections 2034.210–2034.310) or treatment from a HEALTH interrogatory? If so, for each estimate or evaluation state:
CARE PROVIDER for any injury you attribute to the (a) the name, ADDRESS, and telephone number of the
INCIDENT? If so, for each HEALTH CARE PROVIDER PERSON who prepared it and the date prepared;
state:
(b) the name, ADDRESS, and telephone number of each
(a) the name, ADDRESS, and telephone number;
PERSON who has a copy of it; and
(b) the type of consultation, examination, or treatment
(c) the amount of damage stated.
provided;
(c) the dates you received consultation, examination, or 7.3 Has any item of property referred to in your answer to
treatment; and interrogatory 7.1 been repaired? If so, for each item state:
(d) the charges to date. (a) the date repaired;
6.5 Have you taken any medication, prescribed or not, as a (b) a description of the repair;
result of injuries that you attribute to the INCIDENT? If so,
(c) the repair cost;
for each medication state:
(d) the name, ADDRESS, and telephone number of the
(a) the name;
PERSON who repaired it;
(b) the PERSON who prescribed or furnished it;
(e) the name, ADDRESS, and telephone number of the
(c) the date it was prescribed or furnished; PERSON who paid for the repair.
(d) the dates you began and stopped taking it; and
8.0 Loss of Income or Earning Capacity
(e) the cost to date.
8.1 Do you attribute any loss of income or earning capacity
6.6 Are there any other medical services necessitated
to the INCIDENT? (If your answer is “no,” do not answer
by the injuries that you attribute to the INCIDENT that
interrogatories 8.2 through 8.8).
were not previously listed (for example, ambulance, nursing,
prosthetics)? If so, for each service state: 8.2 State:
(a) the nature; (a) the nature of your work;
(b) the date; (b) your job title at the time of the INCIDENT; and
(c) the cost; and (c) the date your employment began.
(d) the name, ADDRESS, and telephone number 8.3 State the last date before the INCIDENT that you
of each provider. worked for compensation.
6.7 Has any HEALTH CARE PROVIDER advised that you
may require future or additional treatment for any injuries 8.4 State your monthly income at the time of the INCIDENT
that you attribute to the INCIDENT? If so, for each injury and how the amount was calculated.
state: 8.5 State the date you returned to work at each place of
(a) the name and ADDRESS of each HEALTH CARE employment following the INCIDENT.
PROVIDER; 8.6 State the dates you did not work and for which you lost
(b) the complaints for which the treatment was income as a result of the INCIDENT.
advised; and
8.7 State the total income you have lost to date as a result
(c) the nature, duration, and estimated cost of
of the INCIDENT and how the amount was calculated.
the treatment.
7.0 Property Damage 8.8 Will you lose income in the future as a result of the
INCIDENT? If so, state:
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 (a) the facts upon which you base this contention;
property: (b) an estimate of the amount;
(a) describe the property; (c) an estimate of how long you will be unable to work;
(b) describe the nature and location of the damage to the and
property;
(d) how the claim for future income is calculated.

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FORM INTERROGATORIES—GENERAL
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9.0 Other Damages (c) the court, names of the parties, and case number of
any action filed;
9.1 Are there any other damages that you attribute to the
(d) the name, ADDRESS, and telephone number of any
INCIDENT? If so, for each item of damage state:
attorney representing you;
(a) the nature; (e) whether the claim or action has been resolved or is
pending; and
(b) the date it occurred;
(f) a description of the injury.
(c) the amount; and 11.2 In the past 10 years have you made a written claim or
(d) the name, ADDRESS, and telephone number of each demand for workers' compensation benefits? If so, for each
PERSON to whom an obligation was incurred. claim or demand state:
(a) the date, time, and place of the INCIDENT giving rise
9.2 Do any DOCUMENTS support the existence or amount to the claim;
of any item of damages claimed in interrogatory 9.1? If so,
(b) the name, ADDRESS, and telephone number of your
describe each document and state the name, ADDRESS,
employer at the time of the injury;
and telephone number of the PERSON who has each
DOCUMENT. (c) the name, ADDRESS, and telephone number of the
workers’ compensation insurer and the claim number;
10.0 Medical History (d) the period of time during which you received workers’
10.1 At any time before the INCIDENT did you have com- compensation benefits;
plaints or injuries that involved the same part of your body (e) a description of the injury;
claimed to have been injured in the INCIDENT? If so, for
(f) the name, ADDRESS, and telephone number of any
each state:
HEALTH CARE PROVIDER who provided services;
(a) a description of the complaint or injury; and
(b) the dates it began and ended; and (g) the case number at the Workers’ Compensation
Appeals Board.
(c) the name, ADDRESS, and telephone number of each
HEALTH CARE PROVIDER whom you consulted or 12.0 Investigation—General
who examined or treated you. 12.1 State the name, ADDRESS, and telephone number of
each individual:
10.2 List all physical, mental, and emotional disabilities you
(a) who witnessed the INCIDENT or the events
had immediately before the INCIDENT. (You may omit
occurring immediately before or after the INCIDENT;
mental or emotional disabilities unless you attribute any
mental or emotional injury to the INCIDENT. ) (b) who made any statement at the scene of the
INCIDENT;
10.3 At any time after the INCIDENT, did you sustain injuries (c) who heard any statements made about the INCIDENT
of the kind for which you are now claiming damages? If so, by any individual at the scene; and
for each incident giving rise to an injury state: (d) who YOU OR ANYONE ACTING ON YOUR
(a) the date and the place it occurred; BEHALF claim has knowledge of the INCIDENT
(except for expert witnesses covered by Code of Civil
(b) the name, ADDRESS, and telephone number of any Procedure section 2034).
other PERSON involved;
12.2 Have YOU OR ANYONE ACTING ON YOUR
(c) the nature of any injuries you sustained; BEHALF interviewed any individual concerning the
(d) the name, ADDRESS, and telephone number of each INCIDENT? If so, for each individual state:
HEALTH CARE PROVIDER who you consulted or who (a) the name, ADDRESS, and telephone number of the
examined or treated you; and individual interviewed;
(b) the date of the interview; and
(e) the nature of the treatment and its duration.
(c) the name, ADDRESS, and telephone number of the
11.0 Other Claims and Previous Claims PERSON who conducted the interview.
12.3 Have YOU OR ANYONE ACTING ON YOUR
11.1 Except for this action, in the past 10 years have you
BEHALF obtained a written or recorded statement from
filed an action or made a written claim or demand for
any individual concerning the INCIDENT? If so, for each
compensation for your personal injuries? If so, for each
statement state:
action, claim, or demand state:
(a) the name, ADDRESS, and telephone number of the
(a) the date, time, and place and location (closest street individual from whom the statement was obtained;
ADDRESS or intersection) of the INCIDENT giving rise (b) the name, ADDRESS, and telephone number of the
to the action, claim, or demand; individual who obtained the statement;
(b) the name, ADDRESS, and telephone number of each (c) the date the statement was obtained; and
PERSON against whom the claim or demand was (d) the name, ADDRESS, and telephone number of each
made or the action filed; PERSON who has the original statement or a copy.

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FORM INTERROGATORIES—GENERAL
 DISC-001
12.4 Do YOU OR ANYONE ACTING ON YOUR BEHALF 13.2 Has a written report been prepared on the
know of any photographs, films, or videotapes depicting any surveillance? If so, for each written report state:
place, object, or individual concerning the INCIDENT or (a) the title;
plaintiff's injuries? If so, state: (b) the date;
(a) the number of photographs or feet of film or videotape; (c) the name, ADDRESS, and telephone number of the
(b) the places, objects, or persons photographed, filmed, individual who prepared the report; and
or videotaped; (d) the name, ADDRESS, and telephone number of each
PERSON who has the original or a copy.
(c) the date the photographs, films, or videotapes were
taken; 14.0 Statutory or Regulatory Violations
14.1 Do YOU OR ANYONE ACTING ON YOUR BEHALF
(d) the name, ADDRESS, and telephone number of the contend that any PERSON involved in the INCIDENT
individual taking the photographs, films, or videotapes; violated any statute, ordinance, or regulation and that the
and violation was a legal (proximate) cause of the INCIDENT?
(e) the name, ADDRESS, and telephone number of each If so, identify the name, ADDRESS, and telephone number
PERSON who has the original or a copy of the of each PERSON and the statute, ordinance, or regulation
photographs, films, or videotapes. that was violated.
12.5 Do YOU OR ANYONE ACTING ON YOUR BEHALF 14.2 Was any PERSON cited or charged with a violation of
know of any diagram, reproduction, or model of any place or any statute, ordinance, or regulation as a result of this
thing (except for items developed by expert witnesses INCIDENT? If so, for each PERSON state:
covered by Code of Civil Procedure sections 2034.210– (a) the name, ADDRESS, and telephone number of the
2034.310) concerning the INCIDENT? If so, for each item PERSON;
state: (b) the statute, ordinance, or regulation allegedly violated;
(a) the type (i.e., diagram, reproduction, or model); (c) whether the PERSON entered a plea in response to
(b) the subject matter; and the citation or charge and, if so, the plea entered; and
(c) the name, ADDRESS, and telephone number of each (d) the name and ADDRESS of the court or administrative
PERSON who has it. agency, names of the parties, and case number.
12.6 Was a report made by any PERSON concerning the 15.0 Denials and Special or Affirmative Defenses
INCIDENT? If so, state: 15.1 Identify each denial of a material allegation and each
special or affirmative defense in your pleadings and for
(a) the name, title, identification number, and employer of
each:
the PERSON who made the report;
(a) state all facts upon which you base the denial or
(b) the date and type of report made;
special or affirmative defense;
(c) the name, ADDRESS, and telephone number of the
(b) state the names, ADDRESSES, and telephone
PERSON for whom the report was made; and
numbers of all PERSONS who have knowledge of
(d) the name, ADDRESS, and telephone number of each those facts; and
PERSON who has the original or a copy of the report. (c) identify all DOCUMENTS and other tangible things
12.7 Have YOU OR ANYONE ACTING ON YOUR that support your denial or special or affirmative
BEHALF inspected the scene of the INCIDENT? If so, for defense, and state the name, ADDRESS, and
each inspection state: telephone number of the PERSON who has each
(a) the name, ADDRESS, and telephone number of the DOCUMENT.
individual making the inspection (except for expert 16.0 Defendant’s Contentions—Personal Injury
witnesses covered by Code of Civil Procedure 16.1 Do you contend that any PERSON, other than you or
sections 2034.210–2034.310); and plaintiff, contributed to the occurrence of the INCIDENT or
(b) the date of the inspection. the injuries or damages claimed by plaintiff? If so, for each
PERSON:
13.0 Investigation—Surveillance (a) state the name, ADDRESS, and telephone number of
13.1 Have YOU OR ANYONE ACTING ON YOUR BEHALF the PERSON;
conducted surveillance of any individual involved in the (b) state all facts upon which you base your contention;
INCIDENT or any party to this action? If so, for each (c) state the names, ADDRESSES, and telephone
surveillance state: numbers of all PERSONS who have knowledge of the
(a) the name, ADDRESS, and telephone number of the facts; and
individual or party; (d) identify all DOCUMENTS and other tangible things
that support your contention and state the name,
(b) the time, date, and place of the surveillance;
ADDRESS, and telephone number of the PERSON
(c) the name, ADDRESS, and telephone number of the who has each DOCUMENT or thing.
individual who conducted the surveillance; and 16.2 Do you contend that plaintiff was not injured in the
(d) the name, ADDRESS, and telephone number of each INCIDENT? If so:
PERSON who has the original or a copy of any (a) state all facts upon which you base your contention;
surveillance photograph, film, or videotape. (b) state the names, ADDRESSES, and telephone
numbers of all PERSONS who have knowledge of the
facts; and
(c) 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.
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 DISC-001
16.3 Do you contend that the injuries or the extent of the 16.8 Do you contend that any of the costs of repairing the
injuries claimed by plaintiff as disclosed in discovery property damage claimed by plaintiff in discovery
proceedings thus far in this case were not caused by the proceedings thus far in this case were unreasonable? If so:
INCIDENT? If so, for each injury: (a) identify each cost item; state all facts upon which you
(a) identify it; base your contention;
(b) state all facts upon which you base your contention;
(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 (c) state the names, ADDRESSES, and telephone
facts; and numbers of all PERSONS who have knowledge of the
(d) identify all DOCUMENTS and other tangible things that facts; and
support your contention and state the name, (d) identify all DOCUMENTS and other tangible things
ADDRESS, and telephone number of the PERSON that support your contention and state the name,
who has each DOCUMENT or thing. ADDRESS, and telephone number of the PERSON
16.4 Do you contend that any of the services furnished by who has each DOCUMENT or thing.
any HEALTH CARE PROVIDER claimed by plaintiff in 16.9 Do YOU OR ANYONE ACTING ON YOUR BEHALF
discovery proceedings thus far in this case were not due to have any DOCUMENT (for example, insurance bureau
the INCIDENT? If so: index reports) concerning claims for personal injuries made
(a) identify each service; before or after the INCIDENT by a plaintiff in this case? If
(b) state all facts upon which you base your contention; so, for each plaintiff state:
(c) state the names, ADDRESSES, and telephone (a) the source of each DOCUMENT;
numbers of all PERSONS who have knowledge of the (b) the date each claim arose;
facts; and
(d) identify all DOCUMENTS and other tangible things that (c) the nature of each claim; and
support your contention and state the name, (d) the name, ADDRESS, and telephone number of the
ADDRESS, and telephone number of the PERSON PERSON who has each DOCUMENT.
who has each DOCUMENT or thing. 16.10 Do YOU OR ANYONE ACTING ON YOUR BEHALF
16.5 Do you contend that any of the costs of services have any DOCUMENT concerning the past or present
furnished by any HEALTH CARE PROVIDER claimed as physical, mental, or emotional condition of any plaintiff in
damages by plaintiff in discovery proceedings thus far in this case from a HEALTH CARE PROVIDER not
this case were not necessary or unreasonable? If so: previously identified (except for expert witnesses covered
(a) identify each cost; by Code of Civil Procedure sections 2034.210–2034.310)?
(b) state all facts upon which you base your contention; If so,for each plaintiff state:
(c) state the names, ADDRESSES, and telephone (a) the name, ADDRESS, and telephone number of each
numbers of all PERSONS who have knowledge of the HEALTH CARE PROVIDER;
facts; and (b) a description of each DOCUMENT; and
(d) identify all DOCUMENTS and other tangible things that
(c) the name, ADDRESS, and telephone number of the
support your contention and state the name,
PERSON who has each DOCUMENT.
ADDRESS, and telephone number of the PERSON
who has each DOCUMENT or thing. 17.0 Responses to Request for Admissions
16.6 Do you contend that any part of the loss of earnings or 17.1 Is your response to each request for admission served
income claimed by plaintiff in discovery proceedings thus far with these interrogatories an unqualified admission? If not,
in this case was unreasonable or was not caused by the for each response that is not an unqualified admission:
INCIDENT? If so:
(a) state the number of the request;
(a) identify each part of the loss;
(b) state all facts upon which you base your response;
(b) state all facts upon which you base your contention;
(c) state the names, ADDRESSES, and telephone (c) state the names, ADDRESSES, and telephone
numbers of all PERSONS who have knowledge of the numbers of all PERSONS who have knowledge of
facts; and those facts; and
(d) identify all DOCUMENTS and other tangible things that (d) identify all DOCUMENTS and other tangible things
support your contention and state the name, that support your response and state the name,
ADDRESS, and telephone number of the PERSON ADDRESS, and telephone number of the PERSON
who has each DOCUMENT or thing. who has each DOCUMENT or thing.
16.7 Do you contend that any of the property damage
18.0 [Reserved]
claimed by plaintiff in discovery Proceedings thus far in this
case was not caused by the INCIDENT? If so: 19.0 [Reserved]
(a) identify each item of property damage; 20.0 How the Incident Occurred—Motor Vehicle
(b) state all facts upon which you base your contention;
(c) state the names, ADDRESSES, and telephone 20.1 State the date, time, and place of the INCIDENT
numbers of all PERSONS who have knowledge of the (closest street ADDRESS or intersection).
facts; and 20.2 For each vehicle involved in the INCIDENT, state:
(d) identify all DOCUMENTS and other tangible things that
(a) the year, make, model, and license number;
support your contention and state the name,
ADDRESS, and telephone number of the PERSON (b) the name, ADDRESS, and telephone number of the
who has each DOCUMENT or thing. driver;
DISC-001 [Rev. January 1, 2008] FORM INTERROGATORIES—GENERAL Page 7 of 8
 DISC-001
(c) the name, ADDRESS, and telephone number of each
occupant other than the driver; (d) state the name, ADDRESS, and telephone number of
each PERSON who has custody of each defective
(d) the name, ADDRESS, and telephone number of each part.
registered owner;
20.11 State the name, ADDRESS, and telephone number
(e) the name, ADDRESS, and telephone number of each of each owner and each PERSON who has had
lessee; possession since the INCIDENT of each vehicle involved in
(f) the name, ADDRESS, and telephone number of each the INCIDENT.
owner other than the registered owner or lien holder; 25.0 [Reserved]
and
30.0 [Reserved]
(g) the name of each owner who gave permission or
consent to the driver to operate the vehicle. 40.0 [Reserved]
20.3 State the ADDRESS and location where your trip 50.0 Contract
began and the ADDRESS and location of your destination. 50.1 For each agreement alleged in the pleadings:
20.4 Describe the route that you followed from the beginning (a) identify each DOCUMENT that is part of the
of your trip to the location of the INCIDENT, and state the agreement and for each state the name, ADDRESS,
location of each stop, other than routine traffic stops, during and telephone number of each PERSON who has the
the trip leading up to the INCIDENT. DOCUMENT;
20.5 State the name of the street or roadway, the lane of (b) state each part of the agreement not in writing, the
travel, and the direction of travel of each vehicle involved in name, ADDRESS, and telephone number of each
the INCIDENT for the 500 feet of travel before the PERSON agreeing to that provision, and the date that
INCIDENT. part of the agreement was made;
20.6 Did the INCIDENT occur at an intersection? If so, (c) identify all DOCUMENTS that evidence any part of the
describe all traffic control devices, signals, or signs at the agreement not in writing and for each state the name,
intersection. ADDRESS, and telephone number of each PERSON
20.7 Was there a traffic signal facing you at the time of the who has the DOCUMENT;
INCIDENT? If so, state: (d) identify all DOCUMENTS that are part of any
(a) your location when you first saw it; modification to the agreement, and for each state the
name, ADDRESS, and telephone number of each
(b) the color; PERSON who has the DOCUMENT;
(c) the number of seconds it had been that color; and (e) state each modification not in writing, the date, and the
(d) whether the color changed between the time you first name, ADDRESS, and telephone number of each
saw it and the INCIDENT. PERSON agreeing to the modification, and the date
the modification was made;
20.8 State how the INCIDENT occurred, giving the speed,
direction, and location of each vehicle involved: (f) identify all DOCUMENTS that evidence any
modification of the agreement not in writing and for
(a) just before the INCIDENT; each state the name, ADDRESS, and telephone
(b) at the time of the INCIDENT; and (c) just after the number of each PERSON who has the DOCUMENT.
INCIDENT.
50.2 Was there a breach of any agreement alleged in the
20.9 Do you have information that a malfunction or defect in pleadings? If so, for each breach describe and give the
a vehicle caused the INCIDENT? If so: date of every act or omission that you claim is the breach of
(a) identify the vehicle; the agreement.

(b) identify each malfunction or defect; 50.3 Was performance of any agreement alleged in the
pleadings excused? If so, identify each agreement excused
(c) state the name, ADDRESS, and telephone number of and state why performance was excused.
each PERSON who is a witness to or has information
about each malfunction or defect; and 50.4 Was any agreement alleged in the pleadings
terminated by mutual agreement, release, accord and
(d) state the name, ADDRESS, and telephone number of satisfaction, or novation? If so, identify each agreement
each PERSON who has custody of each defective part. terminated, the date of termination, and the basis of the
20.10 Do you have information that any malfunction or termination.
defect in a vehicle contributed to the injuries sustained in 50.5 Is any agreement alleged in the pleadings
the INCIDENT? If so: unenforceable? If so, identify each unenforceable
(a) identify the vehicle; agreement and state why it is unenforceable.
(b) identify each malfunction or defect; 50.6 Is any agreement alleged in the pleadings
ambiguous? If so, identify each ambiguous agreement and
(c) state the name, ADDRESS, and telephone number of
state why it is ambiguous.
each PERSON who is a witness to or has information
about each malfunction or defect; and 60.0 [Reserved]

DISC-001 [Rev. January 1, 2008] Page 8 of 8

FORM INTERROGATORIES—GENERAL
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