DISC-001: California Form Interrogatories-General

Enter the attorney or party without attorney State Bar Number, Name, Firm Name, Street Address, City, State, Zip Code, Telephone No., Fax No., Email Address and Attorney for (name).

Enter the Superior Court of California, County of, the Short Title of Case and the Case Number.

Enter the Asking Party, the Answering Party and the Set No.

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.

Or check (2) INCIDENT means and insert your definition there or on a separate, attached sheet labeled “Sec. 4(a)(2)”.

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.

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. Additional interrogatories may be attached.

The interrogatories are in 1.0 Identity of Persons Answering These Interrogatories, 2.0 General Background Information-Individual, 3.0 General Background Information-Business Entity, 4.0 Insurance, 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, 20.0 How the Incident Occurred-Motor Vehicle and 50.0 Contract. 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] and Family Law [See separate form FL-145].

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.

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.

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.

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.

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.

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).

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).

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. )

You may wish to use a form at the end of your answers.

By signing you declare under penalty of perjury that your answers are true and correct. (Date) (SIGNATURE)

An answer or other appropriate response must be given to each interrogatory checked by the asking party.

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.

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.