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

DISC-001

TELEPHONE NO.:

FAX NO. (Optional):

E-MAIL ADDRESS (Optional):

ATTORNEY FOR (Name):

SUPERIOR COURT OF CALIFORNIA, COUNTY OF

SHORT TITLE OF CASE:

Asking Party:

Answering Party: 

 Set No.:

FORM INTERROGATORIES—GENERAL

CASE NUMBER:

Sec. 1. 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.

(b)   For time limitations, requirements for service on other   
parties, and other details, see Code of Civil Procedure  
sections 2030.010–2030.410 and 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—Limited Civil Cases (Economic Litigation) 
(form DISC-004), 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–Personal 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.
(b)   As a general rule, within 30 days after you are served   

with these interrogatories, you must serve your responses on  
the asking party and serve copies of your responses on all  
other parties to the action who have appeared. See Code of  
Civil Procedure sections 2030.260–2030.270 for details.

(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.

(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 or  
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 California that the foregoing answers are true and  
correct.

(Date)

(SIGNATURE)

Sec. 4.  Definitions
Words in BOLDFACE CAPITALS in these interrogatories are 
defined as follows:

(a)  (Check one of the following):

(1) INCIDENT includes the circumstances and 
events surrounding the alleged accident, injury, or 
other occurrence or breach of contract giving rise to 
this action or proceeding.

Form Approved for Optional Use  
Judicial Council of California  
DISC-001 [Rev. January 1, 2008]

FORM INTERROGATORIES—GENERAL

Page 1 of 8

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.  
4(a)(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 means a 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(e)(3).

(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:

1.0  Identity of Persons Answering These Interrogatories 
2.0  General Background Information—Individual 
3.0  General Background Information—Business Entity 
4.0  Insurance
5.0  [Reserved]
6.0  Physical, Mental, or Emotional Injuries
7.0  Property Damage
8.0  Loss of Income or Earning Capacity 
9.0  Other Damages
10.0  Medical History
11.0  Other Claims and Previous Claims 
12.0  Investigation—General              
13.0  Investigation—Surveillance
14.0 Statutory or Regulatory Violations
15.0  Denials and Special or Affirmative Defenses 
16.0  Defendant’s Contentions Personal Injury 
17.0  Responses to Request for Admissions 
18.0 [Reserved]
19.0 [Reserved]
20.0 How the Incident Occurred—Motor Vehicle
25.0 [Reserved]
30.0 [Reserved]
40.0 [Reserved]
50.0 Contract
60.0 [Reserved]
70.0 Unlawful Detainer [See separate form DISC-003] 
101.0 Economic Litigation [See separate form DISC-004]
200.0 Employment Law [See separate form DISC-002] Family 

Law [See separate form FL-145]

DISC-001

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.)

2.0 General Background Information individual—

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; 

(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 self-employment; and

(b)   the name, ADDRESS, dates of employment, job title, 

and nature of work for each employer or self-
employment you have had from five years before the 
INCIDENT until today.

2.7 State:
(a)   the name and ADDRESS of each school or other       
academic or vocational institution you have attended, 
beginning with high school;

(b)   the dates you attended; 
(c)   the highest grade level you have completed; and 
(d)   the degrees received.

2.8 Have you ever been convicted of a felony? If so, for 
each conviction state: 
(a)   the city and state where you were convicted; 
(b)   the date of conviction;
(c)   the offense; and
(d)   the court and case number.

2.9 Can you speak English with ease? If not, what 
language and dialect do you normally use?

2.10 Can you read and write English with ease? If not, 
what language and dialect do you normally use?

CONTENTS

and 

DISC-001 [Rev. January 1, 2008]

FORM INTERROGATORIES—GENERAL

Page 2 of 8

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)   a 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;

taken;

(e)   the ADDRESS where each substance was used or 

(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.

3.1 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; and 
(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 and the dates each was used;

(c)   whether you are a limited partnership and, if so,  under 

the laws of what jurisdiction; 

(d)   the name and ADDRESS of each general partner; and 

(e)   the ADDRESS of the principal place of business.
3.3 Are you a limited liability company? If so, state:
(a)   the name stated in the current articles of organization;

years and the date each was used;

(c)   the date and place of filing of the articles of organization;

(d)   the ADDRESS of the principal place of business; and 
(e)   whether you are qualified to do business in California.

3.0  General Background Information—Business Entity

4.0  Insurance

DISC-001

3.4 Are you a joint venture? If so, state:

(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 other 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     
registered 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.

4.1 At the time of the INCIDENT, was there in effect any 
policy of insurance through which you were or might be  
insured in any manner (for example, primary, pro-rata, or  
excess liability coverage or medical expense coverage) for 
the damages, claims, or actions that have arisen out of the 
INCIDENT? 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 you self-insured under any statute for the damages, 
claims, or actions that have arisen out of the  INCIDENT? If 
so, specify the statute.

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.

(b)   all other names used by the company during the past 10 

6.0 Physical, Mental, or Emotional Injuries

5.0 [Reserved]

DISC-001 [Rev. January 1, 2008]

FORM INTERROGATORIES—GENERAL

Page 3 of 8

DISC-001

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:

(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 

(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.

(c)   the dates you received consultation, examination, or 

7.3 Has any item of property referred to in your answer to 
interrogatory 7.1 been repaired? If so, for each item state: 

provided;

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.

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;

(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-001 [Rev.  January 1, 2008]

FORM INTERROGATORIES—GENERAL

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

11.1 Except for this action, in the past 10 years have you  
filed an action or made a written claim or demand for  
compensation for your personal injuries? 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;

Appeals Board.

12.0 Investigation—General

DISC-001

(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 or  
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 your 

employer at the time of the injury;

(c)   the name, ADDRESS, and telephone number of the 
workers’ compensation insurer and the claim number;
(d)   the period of time during which you received workers’ 

compensation benefits;

(e)   a description of the injury;

(f)   the name, ADDRESS, and telephone number of any 

HEALTH CARE PROVIDER who provided services; and

(g)   the case number at the Workers’ Compensation 

12.1 State the name, ADDRESS, and telephone number of 
each individual:

(a)   who witnessed the INCIDENT or the events  occurring 

immediately before or after the INCIDENT;

(b)   who made any statement at the scene of the INCIDENT;
(c)   who heard any statements made about the INCIDENT 

by any individual at the scene; 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 concerning the  
INCIDENT? If so, for each individual state:
(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-001 [Rev. January 1, 2008]

FORM INTERROGATORIES—GENERAL

Page 5 of 8

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;

taken;

(c)   the date the photographs, films, or videotapes were       

14.0 Statutory or Regulatory Violations

(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 2034.210– 
2034.310) 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? If so, for  
each inspection state:
(a)   the name, ADDRESS, and telephone number of the 
individual making the inspection (except for expert  
witnesses covered by Code of Civil Procedure   
sections 2034.210–2034.310); and

(b)   the date of the inspection.

13.0 Investigation—Surveillance

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 sur-
veillance 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-001

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 the     

individual who prepared the report; and

(d)   the name, ADDRESS, and telephone number of each  

PERSON who has the original or a copy.

14.1 Do YOU OR ANYONE ACTING ON YOUR BEHALF 
contend that any PERSON involved in the INCIDENT  
violated any statute, ordinance, or regulation and that the  
violation was a legal (proximate) cause of the INCIDENT? If 
so, identify the name, ADDRESS, and telephone number of 
each PERSON and the statute, ordinance, or regulation that 
was violated.
14.2 Was any PERSON cited or charged with a violation of 
any statute, ordinance, or regulation as a result of this  
INCIDENT? If so, for each PERSON state:
(a)   the name, ADDRESS, and telephone number of the 

PERSON;

(b)   the statute, ordinance, or regulation allegedly violated;
(c)   whether the PERSON entered a plea in response to the 
citation or charge and, if so, the plea entered; and
(d)   the name and ADDRESS of the court or administrative 

agency, names of the parties, and case number.

15.0 Denials and Special or Affirmative Defenses

15.1 Identify each denial of a material allegation and each 
special or affirmative defense in your pleadings and for 
each:
(a)   state all facts upon which you base the denial or special 

or affirmative defense;

(b)   state the names, ADDRESSES, and telephone numbers 
of all PERSONS who have knowledge of those facts; 
and

(c)   identify all DOCUMENTS and other tangible things that 

support your denial or special or affirmative defense, and 
state the name, ADDRESS, and telephone number of 
the PERSON who has each  DOCUMENT.

16.0 Defendant’s Contentions—Personal Injury

16.1 Do you contend that any PERSON, other than you or  
plaintiff, contributed to the occurrence of the INCIDENT or  
the injuries or damages claimed by plaintiff? If so, for each  
PERSON:
(a)   state the name, ADDRESS, and telephone number of 

the PERSON;

(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.

16.2 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 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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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.

16.4 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-001

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 by a 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—Motor Vehicle

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 number; 
(b)   the name, ADDRESS, and telephone number of  the 

driver;

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FORM INTERROGATORIES—GENERAL

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(c)   the name, ADDRESS, and telephone number of each 

occupant other than the driver;

(d)   the name, ADDRESS, and telephone number of each    

(e)   the name, ADDRESS, and telephone number of each    

registered owner;

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 there a 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;

DISC-001

(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 unenforce-
able? 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.

(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

60.0 [Reserved]

DISC-001 [Rev. January 1, 2008]

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