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

DISC-002

SUPERIOR COURT OF CALIFORNIA, COUNTY OF

TELEPHONE NO.:

FAX NO. (Optional):

E-MAIL ADDRESS (Optional):

ATTORNEY FOR (Name):

SHORT TITLE:

Asking Party:

Answering Party: 

 Set No.:

FORM INTERROGATORIES – EMPLOYMENT LAW

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 employment cases.

(d)

(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 form interrogatories are designed for optional use by 

parties in employment cases. (Separate sets of  
interrogatories, Form Interrogatories—General (form  
DISC-001) and Form Interrogatories—Limited Civil Cases  
(Economic Litigation) (form DISC-004) may also be used 
where applicable in employment cases.)
Insert the names of the EMPLOYEE and EMPLOYER to 
whom these interrogatories apply in the definitions in sections 
4(d) and (e) below.

(b)

(c) 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.

(d) The interrogatories in section 211.0, Loss of  

Income Interrogatories to Employer, should not be used  
until the employer has had a reasonable opportunity to 
conduct an investigation or discovery of the employee’s 
injuries and damages.

(e) Additional interrogatories may be attached.

Sec. 3. Instructions to the Answering Party
(a) You must answer or provide another appropriate response to 

each interrogatory that has been checked below.

(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 permits. If  
an interrogatory cannot be answered completely,  
answer it to the extent possible.
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) PERSON includes a natural person, firm, association, 

organization, partnership, business, trust, limited liability  
company, corporation, or public entity.

Form Approved for Optional Use  
Judicial Council of California  
DISC-002 [Rev. January 1, 2009]

FORM INTERROGATORIES–EMPLOYMENT LAW

Page 1 of 8

Code of Civil Procedure,  §§ 
2030.010–2030.410, 2033.710 

(b)   YOU OR ANYONE ACTING ON YOUR BEHALF includes 

Sec. 5. Interrogatories 

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.

The following interrogatories for employment law cases have  
been approved by the Judicial Council under Code of Civil  
Procedure section 2033.710:

DISC-002

(c)   EMPLOYMENT means a relationship in which an 

EMPLOYEE provides services requested by or on behalf of  
an EMPLOYER, other than an independent contractor 
relationship.

(d)  

EMPLOYEE means a PERSON who provides services in an 
EMPLOYMENT relationship and who is a party to this lawsuit. 
For purposes of these interrogatories, EMPLOYEE refers to 
(insert name):

(If no name is inserted, EMPLOYEE means all such  
PERSONS.)

(e)   EMPLOYER means a PERSON who employs an 

EMPLOYEE to provide services in an EMPLOYMENT  
relationship and who is a party to this lawsuit. For purposes 
of these interrogatories, EMPLOYER refers to (insert name):

(If no name is inserted, EMPLOYER means all such  
PERSONS.)

(f)    ADVERSE EMPLOYMENT ACTION means any 

TERMINATION, suspension, demotion, reprimand, loss of  
pay, failure or refusal to hire, failure or refusal to promote, or  
other action or failure to act that adversely affects the  
EMPLOYEE’S rights or interests and which is alleged in the  
PLEADINGS .

(g)   TERMINATION means the actual or constructive termination 
of employment and includes a discharge, firing, layoff,  
resignation, or completion of the term of the employment 
agreement.

(h)   PUBLISH means to communicate orally or in writing to 

anyone other than the plaintiff. This includes communications  
by one of the defendant’s employees to others. (Kelly v. 
General Telephone Co. (1982) 136 Cal.App.3d 278, 284.)

(i)    PLEADINGS means the original or most recent amended 

version of any complaint, answer, cross-complaint, or answer  
to cross-complaint.

(j) BENEFIT means any benefit from an EMPLOYER, including 
an “employee welfare benefit plan” or employee pension 
benefit plan” within the meaning of Title 29 United States 
Code section 1002(1) or (2) or ERISA.

(k) HEALTH CARE PROVIDER includes any PERSON referred 

to in Code of Civil Procedure section 667.7(e)(3).

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.

(m)  ADDRESS means the street address, including the city, state, 

and zip code.

CONTENTS

200.0 Contract Formation

201.0 Adverse Employment Action

202.0 Discrimination Interrogatories to Employee 

203.0 Harassment Interrogatories to Employee

204.0 Disability Discrimination

205.0 Discharge in Violation of Public Policy 

206.0 Defamation 

207.0 Internal Complaints

208.0 Governmental Complaints

210.0 Loss of income Interrogatories to Employee

211.0 Loss of income Interrogatories to Employer

212.0 Physical, Mental, or Emotional Injuries— 
          Interrogatories to Employee 

213.0 Other Damages Interrogatories to Employee 

214.0 Insurance

215.0 Investigation

216.0 Denials and Special or Affirmative Defenses 

217.0 Response to Request for Admissions

200.0 Contract Formation

209.0 Other Employment Claims by Employee or Against             
Employer

200.1 Do you contend that the EMPLOYMENT relationship 
was at “at will”? If so:
(a) state all facts upon which you base this  

contention;

(b)   state the name, ADDRESS, and telephone number of 
each PERSON who has knowledge of those facts; and

(c)   identify all DOCUMENTS that support your  

contention.

200.2 Do you contend that the EMPLOYMENT  
relationship was not “at will”? If so: 

(a) state all facts upon which you base this  

contention; 

(b)   state the name, ADDRESS, and telephone number of 
each PERSON who has knowledge of those facts; and

(c)   identify all DOCUMENTS that support your   

200.3 Do you contend that the EMPLOYMENT   
relationship was governed by any  
agreement—written, oral, or implied? If so:
(a) state all facts upon which you base this  

contention; 

(b)   state the name, ADDRESS, and telephone number of 
each PERSON who has knowledge of those facts; and

(c)   identify all DOCUMENTS that support your  

contention.

(l) DOCUMENT means a writing, as defined in Evidence Code 

contention.

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FORM INTERROGATORIES–EMPLOYMENT LAW

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(c)   state the manner, if any, in which employees  

(d)   identify all DOCUMENTS that evidence these specific 

200.4 Was any part of the parties’ EMPLOYMENT  
relationship governed in whole or in part by any  
written rules, guidelines, policies, or procedures  
established by the EMPLOYER? If so, for each 
DOCUMENT containing the written rules,  
guidelines, policies, or procedures:
(a) state the date and title of the DOCUMENT and  

a general description of its contents;

(b)   state the manner in which the DOCUMENT was 

communicated to employees; and

acknowledged either receipt of the DOCUMENT  
or knowledge of its contents.

200.5 Was any part of the parties’ EMPLOYMENT  
relationship covered by one or more collective  
bargaining agreements or memorandums of  
understanding between the EMPLOYER (or an  
association of employers) and any labor union or  
employee association? If so, for each collective  
bargaining agreement or memorandum of   
understanding, state:
(a)

the names and ADDRESSES of the parties to the 
collective bargaining agreement or memorandum of 
understanding;

(b)   the beginning and ending dates, if applicable, of the  
collective bargaining agreement or memorandum of 
understanding; and

(c)   which parts of the collective bargaining agreement or  
memorandum of understanding, if any, govern (1)  
any dispute or claim referred to in the PLEADINGS 
and (2) the rules or procedures for resolving any 
dispute or claim referred to in the PLEADINGS .
200.6 Do you contend that the EMPLOYEE and the  
EMPLOYER were in a business relationship other  
than an EMPLOYMENT relationship? If so, for each 
relationship:
(a) state the names of the parties to the relationship;

(b)   identify the relationship; and 

(c)   state all facts upon which you base your contention  
that the parties were in a relationship other than an  
EMPLOYMENT relationship.

201.1 Was the EMPLOYEE involved in a TERMINATION? 
If so:

(a) state all reasons for the EMPLOYEE’S 

TERMINATION;

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

each PERSON who participated in the  
TERMINATION  decision;

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

each PERSON who provided any information relied  
upon in the TERMINATION decision; and 

(d)   identify all DOCUMENTS relied upon in the  

TERMINATION decision.

201.0 Adverse Employment Action

DISC-002

201.2 Are there any facts that would support the  
EMPLOYEE’S TERMINATION that were first  
discovered after the TERMINATION? If so:

(a) state the specific facts;

(b)   state when and how EMPLOYER first learned of  

each specific fact;

(c)   state the name, ADDRESS, and telephone number of  
each PERSON who has knowledge of the specific  
facts; and

facts.

201.3 Were there any other ADVERSE  
EMPLOYMENT ACTIONS, including (the  
asking party should list the  ADVERSE  
EMPLOYMENT ACTIONS):

If so, for each action, provide the following:
(a) all reasons for each ADVERSE EMPLOYMENT 

ACTION; 

(b)   the name, ADDRESS, and telephone number of  
each  PERSON who participated in making each 
ADVERSE EMPLOYMENT ACTION decision; 

(c)   the name, ADDRESS, and telephone number  

of each PERSON who provided any information  
relied upon in making each ADVERSE  
EMPLOYMENT ACTION  decision; and 

(d)   the identity of all DOCUMENTS relied upon in  
making each ADVERSE EMPLOYMENT  
ACTION decision.

201.4 Was the TERMINATION or any other  
ADVERSE EMPLOYMENT ACTIONS referred to in 
Interrogatories 201.1 through 201.3 based in whole or in 
part on the  EMPLOYEE'S job performance? If so, for each 
action:
(a)

identify the ADVERSE EMPLOYMENT ACTION;

(b)   identify the EMPLOYEE'S specific job  

performance that played a role in that ADVERSE 
EMPLOYMENT ACTION;

(c)   identify any rules, guidelines, policies, or   
procedures that were used to evaluate the 
EMPLOYEE’S specific job performance;

(d)   state the names, ADDRESSES, and telephone  

numbers of all PERSONS who had responsibility for  
evaluating the specific job performance of the 
EMPLOYEE;

(e)   state the names, ADDRESSES, and telephone 

numbers of all PERSONS who have knowledge of the  
EMPLOYEE'S specific job performance that played a  
role in that ADVERSE EMPLOYMENT ACTION; and

(f) describe all warnings given with respect to the  

EMPLOYEE’S specific job performance.

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201.5 Was any PERSON hired to replace the  
EMPLOYEE after the EMPLOYEE’S  
TERMINATION or demotion? If so, state the  
PERSON'S name, job title, qualifications,  
ADDRESS and telephone number, and the  
date the PERSON was hired.
201.6 Has any PERSON performed any of the  
EMPLOYEE’S former job duties after the  
EMPLOYEE’S TERMINATION or demotion? If so: 

(a) state the PERSON’S name, job title,  

ADDRESS, and telephone number;

(b)   identify the duties; and

(c)   state the date on which the PERSON started to  

perform the duties.

201.7 If the ADVERSE EMPLOYMENT ACTION involved  
the failure or refusal to select the EMPLOYEE (for  
example, for hire, promotion, transfer, or training), was  
any other PERSON selected instead? If so, for each 
ADVERSE EMPLOYMENT ACTION, state the name, 
ADDRESS, and telephone number of each PERSON 
selected; the date the  PERSON was selected; and the 
reason the PERSON was selected instead of the 
EMPLOYEE .

202.0 Discrimination—Interrogatories to Employee

202.1 Do you contend that any ADVERSE 
EMPLOYMENT ACTIONS against you were 
discriminatory? If so:

(a)

identify each ADVERSE EMPLOYMENT  
ACTION that involved unlawful discrimination; 

(b)   identify each characteristic (for example, gender,  
race, age, etc.) on which you base your claim or  
claims of discrimination;

(c)   state all facts upon which you base each claim  

of discrimination;

(d)   state the name, ADDRESS, and telephone number of  
each PERSON with knowledge of those facts; and 

(e)   identify all DOCUMENTS evidencing those facts.

202.2 State all facts upon which you base your contention  
that you were qualified to perform any job which you  
contend was denied to you on account of unlawful  
discrimination.

203.0 Harassment—Interrogatories to Employee

203.1Do you contend that you were unlawfully harassed in 
your employment? If so:

(a) state the name, ADDRESS, telephone number, and 

employment position of each PERSON whom you 
contend harassed you;

(b)   for each PERSON whom you contend harassed you,  

describe the harassment;

DISC-002

(c)   identify each characteristic (for example, gender,  

race, age, etc.) on which you base your claim of 
harassment;

(d)   state all facts upon which you base your  

contention that you were unlawfully harassed; 

(e)   state the name, ADDRESS, and telephone  

number of each PERSON with knowledge of those 
facts; and

(f)    identify all DOCUMENTS evidencing those facts.

204.0 Disability Discrimination

204.1 Name and describe each disability alleged in the  
PLEADINGS .

204.2 Does the EMPLOYEE allege any injury or illness  
that arose out of or in the course of EMPLOYMENT?  
If so, state:

(a)

the nature of such injury or illness;

(b)   how such injury or illness occurred; 

(c)   the date on which such injury or illness  

occurred;

(d)   whether EMPLOYEE has filed a workers’  

compensation claim. If so, state the date and  
outcome of the claim; and

(e)   whether EMPLOYEE has filed or applied for disability 

benefits of any type. If so, state the  
date, identify the nature of the benefits applied  
for, and the outcome of any such application.

204.3 Were there any communications between the  
EMPLOYEE (or the EMPLOYEE’S HEALTH CARE  
PROVIDER) and the EMPLOYER about the type or  
extent of any disability of EMPLOYEE? If so:

(a) state the name, ADDRESS, and telephone  

number of each person who made or received  
the communications;

(b)   state the name, ADDRESS, and telephone number of 
each PERSON who witnessed the communications;

(c)   describe the date and substance of the 

communications; and

(d)   identify each DOCUMENT that refers to the 

communications.

204.4 Did the EMPLOYER have any information  
about the type, existence, or extent of any disability of 
EMPLOYEE  other than from communications with the 
EMPLOYEE or the EMPLOYEE’S HEALTH CARE 
PROVIDER? If so, state the sources and substance of  
that information and the name, ADDRESS, and  
telephone number of each PERSON who provided or 
received the information.

204.5 Did the EMPLOYEE need any  
accommodation to perform any function of the 
EMPLOYEE’S job position or need a transfer to  
another position as an accommodation? If so,  
describe the accommodations needed.

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204.6 Were there any communications between the  
EMPLOYEE (or the EMPLOYEE’S HEALTH CARE  
PROVIDER) and the EMPLOYER about any possible  
accommodation of EMPLOYEE? If so, for each 
communication:
(a) state the name, ADDRESS, and telephone  
number of each PERSON who made or  
received the communication;

(b)   state the name, ADDRESS, and telephone   
number of each PERSON who witnessed the 
communication;

(c)   describe the date and substance of the  

communication; and

(d)   identify each DOCUMENT that refers to the  

communication.

204.7 What did the EMPLOYER consider doing to  
accommodate the EMPLOYEE? For each  
accommodation considered:
(a) describe the accommodation considered;

(b)   state whether the accommodation was offered to the 

EMPLOYEE;

(c)   state the EMPLOYEE’S response; or

(d)   if the accommodation was not offered, state all the 

reasons why this decision was made;

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

each PERSON who on behalf of EMPLOYER made  
any decision about what accommodations, if any, to 
make for the EMPLOYEE; and

(f)    state the name, ADDRESS, and telephone number of  
each PERSON who on behalf of the EMPLOYER  
made or received any communications about what  
accommodations, if any, to make for the  
EMPLOYEE .

205.0 Discharge in Violation of Public Policy

205.1 Do you contend that the EMPLOYER took any  
ADVERSE EMPLOYMENT ACTION against you in  
violation of public policy? If so:

(a)

identify the constitutional provision, statute,  
regulation, or other source of the public policy that  
you contend was violated; and

(b)   state all facts upon which you base your contention  

that the EMPLOYER violated public policy.

206.0 Defamation

206.1 Did the EMPLOYER'S agents or employees  
PUBLISH any of the allegedly defamatory statements  
identified in the PLEADINGS? If so, for each  
statement: 

(a)

identify the PUBLISHED statement; 

(b)   state the name, ADDRESS, telephone number, and  

job title of each person who PUBLISHED the 
statement;

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

each person to whom the statement was  
PUBLISHED;

DISC-002

207.0 Internal Complaints

(d)   state whether, at the time the statement was 

PUBLISHED, the PERSON who PUBLISHED the 
statement believed it to be true; and

(e)   state all facts upon which the PERSON who  

published the statement based the belief that it was 
true.

206.2 State the name and ADDRESS of each agent or  
employee of the EMPLOYER who responded to any  
inquiries regarding the EMPLOYEE after the  
EMPLOYEE’S TERMINATION.

206.3 State the name and ADDRESS of the recipient  
and the substance of each post-TERMINATION  
statement  PUBLISHED about EMPLOYEE by any  
agent or employee of EMPLOYER.

207.1 Were there any internal written policies or  
regulations of the EMPLOYER that apply to the making  
of a complaint of the type that is the subject matter of  
this lawsuit? If so:

(a) state the title and date of each DOCUMENT  
containing the policies or regulations and a  
general description of the DOCUMENT’S  
contents;

(b)   state the manner in which the DOCUMENT was 

communicated to EMPLOYEES;

(c)   state the manner, if any, in which EMPLOYEES  
acknowledged receipt of the DOCUMENT or  
knowledge of its contents, or both;

(d)   state, if you contend that the EMPLOYEE failed  

to use any available internal complaint  
procedures, all facts that support that  
contention; and

(e)   state, if you contend that the EMPLOYEE’S failure to 

use internal complaint procedures was excused, all 
facts why the EMPLOYEE’S use of the procedures was 
excused.

207.2 Did the EMPLOYEE complain to the  
EMPLOYER about any of the unlawful conduct  
alleged in the PLEADINGS? If so, for each  
complaint:

(a) state the date of the complaint; 

(b)   state the nature of the complaint; 

(c)   state the name and ADDRESS of each  

PERSON to whom the complaint was made; 

(d)   state the name, ADDRESS, telephone number,  
and job title of each PERSON who investigated  
the complaint;

(e)   state the name, ADDRESS, telephone number,  

and job title of each PERSON who participated in 
making decisions about how to conduct the 
investigation;

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(f)   state the name, ADDRESS, telephone number,  

and job title of each PERSON who was  
interviewed or who provided an oral or written 
statement as part of the investigation of the  
complaint;

(g)   state the nature and date of any action taken in 

response to the complaint;

(h)   state whether the EMPLOYEE who made the  

complaint was made aware of the actions taken  
by the  EMPLOYER in response to the  
complaint, and, if so, state how and when; 

(i)  

identify all DOCUMENTS relating to the  
complaint, the investigation, and any action  
taken in response to the complaint; and 

(j)    state the name, ADDRESS, and telephone  

number of each PERSON who has knowledge  
of the  EMPLOYEE’S complaint or the  
EMPLOYER'S  response to the complaint.

208.0   Governmental Complaints

208.1 Did the EMPLOYEE file a claim, complaint, or charge 
with any governmental agency that involved any of the  
material allegations made in the PLEADINGS? If so, for 
each claim, complaint, or charge:

(a) state the date on which it was filed;

(b)   state the name and ADDRESS of the agency with 

which it was filed;

(d)   state the name, ADDRESS, telephone number, and  
job title of each PERSON who was interviewed or  
who provided an oral or written statement as part of  
the investigation.

DISC-002

209.0 Other Employment Claims by Employee or  
          Against Employer

209.1 Except for this action, in the past 10 years has the 
EMPLOYEE filed a civil action against any  
employer regarding the EMPLOYEE’S employment? If  
so, for each civil action:

(a) state the name, ADDRESS, and telephone  
number of each employer against whom the  
action was filed;

(b)   state the court, names of the parties, and case  

number of the civil action;

(c)   state the name, ADDRESS, and telephone  
number of any attorney representing the  
EMPLOYEE; and

(d)  

state whether the action has been resolved  
or is pending.

209.2 Except for this action, in the past 10 years has any 
employee filed a civil action against the EMPLOYER  
regarding his or her employment? If so, for each civil action:

(c)   state the number assigned to the claim, complaint, or 

charge by the agency;

(a) state the name, ADDRESS, and telephone  

number of each employee who filed the action; 

(g)   state whether a right to sue notice was issued and, if 

210.0 Loss of Income—Interrogatories to Employee

(d)   state the nature of each claim, complaint, or charge 

made;

(e)   state the date on which the EMPLOYER was  
notified of the claim, complaint, or charge;

(f)   state the name, ADDRESS, and telephone number of  
all PERSONS within the governmental agency with  
whom the EMPLOYER has had any contact or  
communication regarding the claim, complaint, or 
charge;

so, when; and

(h)   state whether any findings or conclusions regarding  
the complaint or charge have been made, and, if so,  
the date and description of the agency’s findings or  
conclusions.

208.2 Did the EMPLOYER respond to any claim,  
complaint, or charge identified in Interrogatory 208.1? If so, 
for each claim, complaint, or charge:

(a) state the nature and date of any investigation done or  

any other action taken by the EMPLOYER in  
response to the claim, complaint, or charge: 

(b)   state the name, ADDRESS, telephone number, and  

job title of each person who investigated the claim, 
complaint, or charge;

(b)   state the court, names of the parties, and case  

number of the civil action; 

(c)   state the name, ADDRESS, and telephone  
number of any attorney representing the  
EMPLOYER; and

(d)   state whether the action has been resolved or  

is pending.

210.1 Do you attribute any loss of income, benefits,  
or earning capacity to any ADVERSE  
EMPLOYMENT ACTION? (If your answer is “no,” do  
not answer Interrogatories 210.2 through 210.6.)

210.2 State the total amount of income, benefits, or  
earning capacity you have lost to date and how the  
amount was calculated.

210.3 Will you lose income, benefits, or earning  
capacity in the future as a result of any ADVERSE 
EMPLOYMENT ACTION? If so, state the total amount  
of income, benefits, or earning capacity you expect to  
lose, and how the amount was calculated.

(c)   state the name, ADDRESS, telephone number, and  
job title of each PERSON who participated in making  
decisions about how to conduct the investigation; and

210.4 Have you attempted to minimize the amount of  
your lost income? If so, describe how; if not,  
explain why not.

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210.5 Have you purchased any benefits to replace  
any benefits to which you would have been entitled if  
the  ADVERSE EMPLOYMENT ACTION had not  
occurred? If so, state the cost for each benefit purchased.

210.6 Have you obtained other employment since any  
ADVERSE EMPLOYMENT ACTION? If so, for each new 
employment:

(a) state when the new employment commenced;

(b)   state the hourly rate or monthly salary for the  

new employment; and 

(c)   state the benefits available from the new  

employment.

211.0 Loss of Income—Interrogatories to Employer  
          [See instruction 2(d).]

211.1 Identify each type of BENEFIT to which the  
EMPLOYEE would have been entitled, from the date  
of the  ADVERSE EMPLOYMENT ACTION to the  
present, if the  ADVERSE EMPLOYMENT ACTION  
had not happened and the EMPLOYEE had  
remained in the same job position. For each type of  
benefit, state the amount the EMPLOYER would  
have paid to provide the benefit for the EMPLOYEE   
during this time period and the value of the BENEFIT  
to the EMPLOYEE.

211.2 Do you contend that the EMPLOYEE has not made  
reasonable efforts to minimize the amount of the  
EMPLOYEE’S lost income? If so:

(a) describe what more EMPLOYEE should have done;

(b)   state the names, ADDRESSES, and telephone 

numbers of all PERSONS who have knowledge of  
the facts that support your contention; and 

(c)   identify all DOCUMENTS that support your  

contention and state the name, ADDRESS, and 
telephone number of the PERSON who has each 
DOCUMENT.

211.3 Do you contend that any of the lost income claimed  
by the EMPLOYEE, as disclosed in discovery thus far  
in this case, is unreasonable or was not caused by  
the ADVERSE EMPLOYMENT ACTION? If so:

(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 that support your 

contention and state the name, ADDRESS, and 
telephone number of the PERSON who has each 
DOCUMENT.

DISC-002

212.0  Physical, Mental, or Emotional Injuries—                 
           Interrogatories to Employee

212.1 Do you attribute any physical, mental, or emotional 
injuries to the ADVERSE EMPLOYMENT ACTION? (If  
your answer is “no,” do not answer Interrogatories 212.2 
through 212.7.)

212.2 Identify each physical, mental, or emotional  
injury that you attribute to the ADVERSE  
EMPLOYMENT ACTION  and the area of your body 
affected.

212.3 Do you still have any complaints of physical,  
mental, or emotional injuries that you attribute to the 
ADVERSE EMPLOYMENT ACTION? If so, for each 
complaint state:

(a) a description of the injury;

(b)   whether the complaint is subsiding, remaining  

the same, or becoming worse; and 

(c)   the frequency and duration.

212.4 Did you receive any consultation or examination  
(except from expert witnesses covered by Code of Civil  
Procedure section 2034) or treatment from a HEALTH  
CARE PROVIDER for any injury you attribute to the  
ADVERSE EMPLOYMENT ACTION? If so, for each 
HEALTH CARE PROVIDER state:

(a)

the name, ADDRESS, and telephone number;

(b)   the type of consultation, examination, or 

treatment provided; 

(c)   the dates you received consultation,  
examination, or treatment; and 

(d)   the charges to date.

212.5 Have you taken any medication, prescribed or  
not, as a result of injuries that you attribute to the  
ADVERSE EMPLOYMENT ACTION? If so, for each 
medication state:

(a)

the name of the medication;

(b)   the name, ADDRESS and telephone number of  
the PERSON who prescribed or furnished it;

(c)   the date prescribed or furnished;

(d)   the dates you began and stopped taking it; and 

212.6 Are there any other medical services not  
previously listed in response to interrogatory 212.4 (for 
example, ambulance, nursing, prosthetics) that you  
received for injuries attributed to the ADVERSE 
EMPLOYMENT ACTION? 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 HEALTH CARE PROVIDER .

(a) state the amount of claimed lost income that you 

(e)   the cost to date.

dispute; 

DISC-002 [Rev. January 1, 2009]

FORM INTERROGATORIES–EMPLOYMENT LAW

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212.7 Has any HEALTH CARE PROVIDER advised  
that you may require future or additional treatment for  
any injuries that you attribute to the ADVERSE 
EMPLOYMENT ACTION? 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

treatment.

(c)   the nature, duration, and estimated cost of the  

213.0 Other Damages—Interrogatories to Employee

213.1 Are there any other damages that you attribute to  
the  ADVERSE EMPLOYMENT ACTION? 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 who has knowledge of the  
nature or amount of the damage.

213.2 Do any DOCUMENTS support the existence or  
amount of any item of damages claimed in Interrogatory  
213.1? If so, identify the DOCUMENTS and state the name,  
ADDRESS, and telephone number of the PERSON who  
has each DOCUMENT.

214.0 Insurance

214.1 At the time of the ADVERSE EMPLOYMENT  
ACTION, was there in effect any policy of insurance  
through which you were or might be insured in any  
manner for the damages, claims, or actions that have  
arisen out of the ADVERSE EMPLOYMENT ACTION?  
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; and

(g)   the name, ADDRESS, and telephone number of  

the custodian of the policy.

214.2 Are you self-insured under any statute for the  
damages, claims, or actions that have arisen out of the  
ADVERSE EMPLOYMENT ACTION? If so, specify the  
statute.

215.0   Investigation

DISC-002

215.1 Have YOU OR ANYONE ACTING ON YOUR  
BEHALF interviewed any individual concerning the  
ADVERSE EMPLOYMENT ACTION? 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.

215.2 Have YOU OR ANYONE ACTING ON YOUR  
BEHALF obtained a written or recorded statement from  
any individual concerning the ADVERSE EMPLOYMENT 
ACTION? 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.

216.0 Denials and Special or Affirmative Defenses

216.1 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 all 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 .

217.0 Response to Request for Admissions

217.1 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.

DISC-002 [Rev.  January 1, 2009]

FORM INTERROGATORIES–EMPLOYMENT LAW

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