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ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
DISC-004
FORM INTERROGATORIES—LIMITED CIVIL CASES (Economic Litigation)
CASE NUMBER:
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.:
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 economic litigation.
(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 under economic litigation in limited civil cases. See
Code of Civil Procedure sections 90 through 100. However,
these interrogatories also may be used in unlimited civil
cases.
(b) There are restrictions on discovery for most limited civil
cases. These restrictions limit the number of interrogatories
that may be asked. For details, read Code of Civil
Procedure section 94.
(c) Some of these interrogatories are similar to questions in the
Case Questionnaire for Limited Civil Cases (form DISC-010)
and may be omitted if the information sought has already
been provided in a completed Case Questionnaire.
(d) Check the box next to each interrogatory that you want the
answering party to answer. Use care in choosing those
interrogatories that apply to the case and are within the
restrictions discussed above.
(e) 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.
(f) The interrogatories in section 116.0, Defendant's Conten-
tions - Personal Injury, should not be used until defendant
has had a reasonable opportunity to conduct an
investigation or discovery of plaintiff's injuries and damages.
(g) Additional interrogatories may be attached, subject to the
restrictions discussed above.
Sec. 3. Instructions to the Answering Party
(a) Subject to the restrictions discussed above, 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 who have appeared. See Code of Civil Procedure
sections 2030.260–2030.270 for details.
(c) Each answer must be as complete and straight-forward as
the information reasonably available to you 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) 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:
(Check one of the following):
(a)
(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-004 [Rev. January 1, 2007]
FORM INTERROGATORIES – LIMITED CIVIL CASES
(Economic Litigation)
Page 1 of 4
Code of Civil Procedure, §§ 94,
2030.010-2030.410, 2033.710
(c) PERSON includes a natural person, firm, association,
organization, partnership, business, trust, corporation, or public
entity.
102.5 State the name, ADDRESS, and telephone number
of each employer you have had over the past five years and
the dates you worked for each.
(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.
(d) DOCUMENT means a writing, as defined in Evidence
Code section 250, and includes the original or a copy of hand-
writing, typewriting, printing, photostating, photographing,
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:
CONTENTS
101.0 Identity of Persons Answering These Interrogatories
102.0 General Background Information - Individual
103.0 General Background Information - Business Entity
104.0 Insurance
105.0 [Reserved]
106.0 Physical, Mental, or Emotional Injuries
107.0 Property Damage
108.0 Loss of Income or Earning Capacity
109.0 Other Damages
110.0 Medical History
111.0 Other Claims and Previous Claims
112.0 Investigation - General
113.0 [Reserved]
114.0 Statutory or Regulatory Violations
115.0 Claims and Defenses
116.0 Defendant's Contentions - Personal Injury
117.0 [Reserved]
120.0 How the Incident Occurred - Motor Vehicle
125.0 [Reserved]
130.0 [Reserved]
135.0 [Reserved]
150.0 Contract
160.0 [Reserved]
170.0 [Reserved]
101.0 Identity of Persons Answering These
Interrogatories
101.1 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.)
102.0 General Background Information - Individual
102.1 State your name, any other names by which you
have been known, and your ADDRESS.
DISC-004
102.2 State the date and place of your birth.
102.3 State, as of the time of the INCIDENT, your driver's
license number, the state of issuance, the expiration date,
and any restrictions.
102.4 State each residence ADDRESS for the last five
years and the dates you lived at each ADDRESS.
102.6 Describe your work for each employer you have had
over the past five years.
102.7 State the name and ADDRESS of each academic or
vocational school you have attended, beginning with high
school, and the dates you attended each.
102.8 If you have ever been convicted of a felony, state, for
each, the offense, the date and place of conviction, and the
court and case number.
102.9 State the name, ADDRESS, and telephone number
of any PERSON for whom you were acting as an agent or
employee at the time of the INCIDENT.
102.10 Describe any physical, emotional, or mental
disability or condition that you had that may have
contributed to the occurrence of the INCIDENT.
102.11 Describe the nature and quantity of any alcoholic
beverage, marijuana, or other drug or medication of any
kind that you used within 24 hours before the INCIDENT.
103.0 General Background Information - Business Entity
103.1 State your current business name and ADDRESS,
type of business entity, and your title.
104.0 Insurance
104.1 State the name and ADDRESS of each insurance
company and the policy number and policy limits of each
policy that may cover you, in whole or in part, for the
damages related to the INCIDENT.
105.0 [Reserved]
106.0 Physical, Mental, or Emotional Injuries
106.1 Describe each injury or illness related to the
INCIDENT.
106.2 Describe your present complaints about each injury
or illness related to the INCIDENT.
106.3 State the name, ADDRESS, and telephone number
of each HEALTH CARE PROVIDER who treated or
examined you for each injury or illness related to the
INCIDENT and the dates of treatment or examination.
DISC-004 [Rev. January 1, 2007]
FORM INTERROGATORIES–LIMITED CIVIL CASES
(Economic Litigation)
Page 2 of 4
106.4 State the type of treatment or examination given to
you by each HEALTH CARE PROVIDER for each injury or
illness related to the INCIDENT.
106.5 State the charges made by each HEALTH CARE
PROVIDER for each injury or illness related to the
INCIDENT.
106.6 State the nature and cost of each health care service
related to the INCIDENT not previously listed (for example,
medication, ambulance, nursing, prosthetics).
106.7 State the nature and cost of the health care services
you anticipate in the future as a result of the INCIDENT.
106.8 State the name and ADDRESS of each HEALTH
CARE PROVIDER who has advised you that you may need
future health care services as a result of the INCIDENT.
107.0 Property Damage
107.1 Itemize your property damage and, for each item,
state the amount or attach an itemized bill or estimate.
108.0 Loss of Income or Earning Capacity
108.1 State the name and ADDRESS of each employer or
other source of the earnings or income you have lost as a
result of the INCIDENT.
108.2 Show how you compute the earnings or income you
have lost, from each employer or other source, as a result of
the INCIDENT.
108.3 State the name and ADDRESS of each employer or
other source of the earnings or income you expect to lose in
the future as a result of the INCIDENT.
108.4 Show how you compute the earnings or income you
expect to lose in the future, from each employer or other
source, as the result of the INCIDENT.
DISC-004
111.0 Other Claims and Previous Claims
111.1 Identify each personal injury claim that YOU OR
ANYONE ACTING ON YOUR BEHALF have made within
the past ten years and the dates.
111.2 State the case name, court, and case number of
each personal injury action or claim filed by YOU OR
ANYONE ACTING ON YOUR BEHALF within the past ten
years.
112.0 Investigation - General
112.1 State the name, ADDRESS, and telephone number
of each individual who has knowledge of facts relating to the
INCIDENT, and specify his or her area of knowledge.
112.2 State the name, ADDRESS, and telephone number
of each individual who gave a written or recorded statement
relating to the INCIDENT and the date of the statement.
112.3 State the name, ADDRESS, and telephone number
of each PERSON who has the original or a copy of a written
or recorded statement relating to the INCIDENT.
112.4 Identify each document or photograph that describes
or depicts any place, object, or individual concerning the
INCIDENT or plaintiff's injuries, or attach a copy. (if you do
not attach a copy, state the name, ADDRESS, and
telephone number of each PERSON who had the original
document or photograph or a copy.)
112.5 Identify each other item of physical evidence that
shows how the INCIDENT occurred or the nature or extent
of plaintiff's injuries, and state the location of each item, and
the name, ADDRESS, and telephone number of each
PERSON who has it.
113.0 [Reserved]
114.0 Statutory or Regulatory Violations
114.1 If you contend that any PERSON involved in the
INCIDENT violated any statute, ordinance, or regulation and
that the violation was a cause of the INCIDENT, identify
each PERSON and the statute, ordinance, or regulation.
115.1 State in detail the facts upon which you base your
claims that the PERSON asking this interrogatory is
responsible for your damages.
115.2 State in detail the facts upon which you base your
contention that you are not responsible, in whole or in part,
for plaintiff's damages.
115.3 State the name, ADDRESS, and the telephone
number of each PERSON, other than the PERSON asking
this interrogatory, who is responsible, in whole or in part, for
damages claimed in this action.
109.0 Other Damages
110.0 Medical History
109.1 Describe each other item of damage or cost that you
attribute to the INCIDENT, stating the dates of occurrence
and the amount.
115.0 Claims and Defenses
110.1 Describe and give the date of each complaint or
injury, whether occurring before or after INCIDENT, that
involved the same part of your body claimed to have been
injured in the INCIDENT.
110.2 State the name, ADDRESS, and telephone number
of each HEALTH CARE PROVIDER who examined or
treated you for each injury or complaint, whether occurring
before or after the INCIDENT, that involved the same part of
your body claimed to have been injured in the INCIDENT
and the dates of examination or treatment.
DISC-004 [Rev. January 1, 2007]
FORM INTERROGATORIES–LIMITED CIVIL CASES
(Economic Litigation)
Page 3 of 4
116.0 Defendant's Contentions - Personal Injury
[See Instruction 2(f)]
116.1 If 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, state the name,
ADDRESS, and telephone number of each individual who
has knowledge of the facts upon which you base your
contention.
116.2 If you contend that plaintiff was not injured in the
INCIDENT, state the name, ADDRESS, and telephone
number of each individual who has knowledge of the facts
upon which you base your contention.
116.3 If you contend that the injuries or the extent of the
injuries claimed by plaintiff were not caused by the
INCIDENT, state the name, ADDRESS, and telephone
number of each individual who has knowledge of the facts
upon which you base your contention.
116.4 If you contend that any of the services furnished by
any HEALTH CARE PROVIDER were not related to the
INCIDENT, state the name, ADDRESS, and telephone
number of each individual who has knowledge of the facts
upon which you base your contention.
116.5 If you contend that any of the costs of services
furnished by any HEALTH CARE PROVIDER were
unreasonable, identify each service that you dispute, the
cost, and the HEALTH CARE PROVIDER.
116.6 If you contend that any part of the loss of earnings or
income claimed by plaintiff was unreasonable, identify each
part of the loss that you dispute and each source of the
income or earnings.
116.7 If you contend that any of the property damage
claimed by plaintiff was not caused by the INCIDENT,
identify each item of property damage that you dispute.
116.8 If you contend that any of the costs of repairing the
property damage claimed by plaintiff were unreasonable,
identify each cost item that you dispute.
11 6.9 If you contend that, within the last ten years, plaintiff
made a claim for personal injuries that are related to the
injuries claimed in the INCIDENT, identify each related injury
and the date.
116.10 If you contend that, within the past ten years,
plaintiff made a claim for personal injuries that are related to
the injuries claimed in the INCIDENT, state the name, court,
and case number of each action filed.
117.0 [Reserved]
120.0 How the Incident Occurred - Motor Vehicle
120.1 State how the INCIDENT occurred.
120.2 For each vehicle involved in the INCIDENT, state the
year, make, model, and license number.
120.3 For each vehicle involved in the INCIDENT, state the
name, ADDRESS, and telephone number of the driver.
DISC-004
120.4 For each vehicle involved in the INCIDENT, state the
name, ADDRESS, and telephone number of each occupant
other than the driver.
120.5 For each vehicle involved in the INCIDENT, state the
name, ADDRESS, and telephone number of each regis-
tered owner.
120.6 For each vehicle involved in the INCIDENT, state the
name, ADDRESS, and telephone number of each lessee.
120.7 For each vehicle involved in the INCIDENT, state the
name, ADDRESS, and telephone number of each owner
other than the registered owner or lien holder.
120.8 For each vehicle involved in the INCIDENT, state the
name of each owner who gave permission or consent to the
driver to operate the vehicle.
150.0 Contract
150.1 Identify all DOCUMENTS that are part of the
agreement and for each state the name, ADDRESS, and
telephone number of the PERSON who has each DOCU-
MENT.
150.2 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.
150.3 Identify all DOCUMENTS that evidence each part of
the agreement not in writing, and for each state the name,
ADDRESS, and telephone number of the PERSON who
has each DOCUMENT.
150.4 Identify all DOCUMENTS that are part of each mod-
ification to the agreement, and for each state the name
ADDRESS, and telephone number of the PERSON who
has each DOCUMENT.
150.5 State each modification not in writing, the date, and
the name, ADDRESS, and telephone number of the
PERSON agreeing to the modification, and the date the
modification was made.
150.6 Identify all DOCUMENTS that evidence each
modification of the agreement not in writing and for each
state the name, ADDRESS, and telephone number of the
PERSON who has each DOCUMENT.
150.7 Describe and give the date of every act or omission
that you claim is a breach of the agreement.
150.8 Identify each agreement excused and state why per-
formance was excused.
150.9 Identify each agreement terminated by mutual agree-
ment and state why it was terminated, including dates.
150.10 Identify each unenforceable agreement and state
the facts upon which your answer is based.
150.11 Identify each ambiguous agreement and state the
facts upon which your answer is based.
DISC-004 [Rev. January 1, 2007]
FORM INTERROGATORIES–LIMITED CIVIL CASES
(Economic Litigation)
Page 4 of 4
