Some checkboxes here already. You represent the plaintiff. Keep that in mind. So, you want to find out information from the defendant? Fill in at least TEN (Ten) boxes on the form.

Sec. 1. Instructions to All Parties (c) Each answer must be as complete and straightforward (a) Interrogatories are written questions prepared by a party as the information reasonably available to you, including the to an action that are sent to any other party in the action to be information possessed by your attomeys or agents, permits. If answered under oath. The interrogatories below are form an interrogatory cannot be answered completely, answer it to interrogatories approved for use in civil cases. the extent possible. (b) For time limitations, requirements for service on other (d) If you do not have enough personal knowledge to fully parties, and other details, see Code of Civil Procedure answer an interrogatory. say so, but make a reasonable and sections 2030.010-2030.410 and the cases construing those good faith effort to get the information by asking other persons sections. or organizations, unless the information is equally available to (c) These form interrogatories do not change existing law the asking party- relating to interrogatories nor do they affect an answering party's right to assert any privilege or make any objection. (e) Whenever an interrogatory may be answered by referring to a document, the document may be attached as an Sec. 2. Instructions to the Asking Party exhibit to the response and referred to in the response. If the (a) These interrogatories are designed for optional use by document has more than one page, refer to the page and parties in unlimited civil cases where the amount demanded section where the answer to the interrogatory can be found. exceeds $35,000. Separate interrogatories, Form Interrogatories-Limited Civil Cases (Economic Litigation) (f) Whenever an address and telephone number for the (form DISC-004). which have no subparts, are designed for same person are requested in more than one interrogatory. use in limited civil cases where the amount demanded is you are required to fumish them in answering only the first $35 000 or less; however, those interrogatories may also be interrogatory asking for that information. used in unlimited civil cases. (g) If you are asserting a privilege or making an objection to (b) Check the box next to each interrogatory that you want an interrogatory. you must specifically assert the privilege or the answering party to answer. Use care in choosing those state the objection in your written response. interrogatories that are applicable to the case. (c) You may insert your own definition of INCIDENT in (h) Your answers to these interrogatories must be verified, Section 4, but only where the action arises from a course of dated, and signed. You may wish to use the following form at the end of your answers: conduct or a series of events occurring over a period of time. (d) The interrogatories in section 16.0, Defendant's I declare under penalty of perjury under the laws of the Contentions-Personal Injury. should not be used until the State of California that the foregoing answers are true and defendant has had a reasonable opportunity to conduct an correct. investigation or discovery of plaintiff's injuries and damages. August 20. 2024 (e) Additional interrogatories may be attached. (Date) (SIGNATURE) Sec. 4. Definitions Sec. 3. Instructions to the Answering Party Words in BOLDFACE CAPITALS in these interrogatories are (a) An answer or other appropriate response must be defined as follows: given to each interrogatory checked by the asking party. (b) As a general rule. within 30 days after you are served (a) (Check one of the following): with these interrogatories, you must serve your responses on (1) INCIDENT includes the circumstances and the asking party and serve copies of your responses on all events surrounding the alleged accident, injury, or other parties to the action who have appeared. See Code of other occurrence or breach of contract giving rise to Civil Procedure sections 2030.260-2030.270 for details. this action or proceeding.x (2) INCIDENT means (insert your definition here or 1.0 Identity of Persons Answering These Interrogatories on a separate, aftached sheet labeled "Sec 4( )(2)7 x 1.1 State the name, ADDRESS, telephone number, and THE SUBJECT ACCIDENT WHEN PLAINTIFF SLIPPED relationship to you of each PERSON who prepared or AND FELL ON THE WOODEN RAMP AT CLASSIC assisted in the preparation of the responses to these PARTY RENTALS' VALLEJO WAREHOUSE. interrogatories. (Do not identify anyone who simply typed or reproduced the responses.) 2.0 General Background Information individual- (b) YOU OR ANYONE ACTING ON YOUR BEHALF 2.1 State: includes you, your agents, your employees, your insurance (a) your name; companies, their agents, their employees, your attomeys, your accountants, your investigators, and anyone else acting (b) every name you have used in the past, and on your behalf. (c) the dates you used each name. (c) PERSON includes a natural person, firm, association, 2.2 State the date and place of your birth. organization, partnership, business, trust, limited liability 2.3 At the time of the INCIDENT, did you have a driver's company. corporation, or public entity- license? If so, state: (d) DOCUMENT means a writing, as defined in Evidence (a) the state or other issuing entity. Code section 250, and includes the original or a copy of (b) the license number and type: handwriting, typewriting, printing. photostats, photographs, (c) the date of issuance; and electronically stored information, and every other means of recording upon any tangible thing and form of communicating (d) all restrictions. or representation, including letters, words. pictures, sounds, 2.4 At the time of the INCIDENT, did you have any other or symbols, or combinations of them. permit or license for the operation of a motor vehicle? If so, (e) HEALTH CARE PROVIDER includes any PERSON state: referred to in Code of Civil Procedure section 867.7(e)(3). (a) the state or other issuing entity. f) ADDRESS means the street address, including the city. (b) the license number and type: state, and zip code. (c) the date of issuance; and Sec. 5. Interrogatories (d) all restrictions. 2.5 State: The following interrogatories have been approved by the Judicial (a) your present residence ADDRESS; Council under Code of Civil Procedure section 2033.710: (b) your residence ADDRESSES for the past five years; CONTENTS and 1.0 Identity of Persons Answering These Interrogatories (c) the dates you lived at each ADDRESS. 2.0 General Background Information-Individual 2.6 State: 3.0 General Background Information-Business Entity (a) the name, ADDRESS, and telephone number of your 4.0 Insurance 5.0 [Reserved] present employer or place of self-employment; and 8.0 Physical, Mental, or Emotional Injuries (b) the name, ADDRESS, dates of employment, job title, 7_0 Property Damage and nature of work for each employer or self- 8.0 Loss of Income or Eaming Capacity employment you have had from five years before the 910 Other Damages INCIDENT until today- 10_0 Medical History 11.0 Other Claims and Previous Claims 2.7 State: 12 0 Investigation-General (a) the name and ADDRESS of each school or other 13.0 Investigation-Surveillance academic or vocational institution you have attended, 14.0 Statutory or Regulatory Violations beginning with high school; 15.0 Denials and Special or Affirmative Defenses (b) the dates you attended 16.0 Defendant's Contentions Personal Injury (c) the highest grade level you have completed; and 17_0 Responses to Request for Admissions 18.0 [Reserved] [d) the degrees received 10.0 [Reserved] 2.8 Have you ever been convicted of a felony? If so, for 20.0 How the Incident Occurred-Motor Vehicle each conviction state: 25.0 [Reserved] (a) the city and state where you were convicted; 30.0 [Reserved] (b) the date of conviction; 40.0 [Reserved] 50.0 Contract (c) the offense; and 60.0 [Reserved] (d) the court and case number. 70.0 Unlawful Detainer [See separate form DISC-003] 2.9 Can you speak English with ease? If not, what 101.0 Economic Litigation [See separate form DISC-004] language and dialect do you normally use? 200.0 Employment Law [See separate form DISC-002] Family 2.10 Can you read and write English with ease? If not, Law [See separate form FL-145] what language and dialect do you normally use?2.11 At the time of the INCIDENT were you acting as an x 3.4 Are you a joint venture? If so, state: agent or employee for any PERSON? If so, state: (a) the current joint venture name (a) the name. ADDRESS, and telephone number of that b) all other names used by the joint venture during the PERSON; and past 10 years and the dates each was used; (b) a description of your duties. (c) the name and ADDRESS of each joint venturer, and 2.12 At the time of the INCIDENT did you or any other (d) the ADDRESS of the principal place of business person have any physical, emotional, or mental disability or condition that may have contributed to the occurrence of the x ] 3.5 Are you an unincorporated association? If so, state: INCIDENT? If so, for each person state: (a) the current unincorporated association name; (a) the name. ADDRESS, and telephone number, b) all other names used by the unincorporated association (b) the nature of the disability or condition; and during the past 10 years and the dates each was used; (c) the manner in which the disability or condition and contributed to the occurrence of the INCIDENT. (c) the ADDRESS of the principal place of business. 2.13 Within 24 hours before the INCIDENT did you or any x ] 3.6 Have you done business under a fictitious name during person involved in the INCIDENT use or take any of the following substances: alcoholic beverage, marijuana, or the past 10 years? If so, for each fictitious name state: other drug or medication of any kind (prescription or not)? If (a) the name; so, for each person state: (b) the dates each was used; (a) the name. ADDRESS, and telephone number, (c) the state and county of each fictitious name filing; and (b) the nature or description of each substance, (d) the ADDRESS of the principal place of business. (c) the quantity of each substance used or taken; x 3.7 Within the past five years has any public entity (d) the date and time of day when each substance was used registered or licensed your business? If so, for each or taken; license or registration: e) the ADDRESS where each substance was used or (a) identify the license or registration; taken; (f) the name. ADDRESS, and telephone number of each (b) state the name of the public entity, and person who was present when each substance was used (c) state the dates of issuance and expiration. or taken; and 4.0 Insurance (g) the name. ADDRESS, and telephone number of any [x ] 4.1 At the time of the INCIDENT, was there in effect any HEALTH CARE PROVIDER who prescribed or fumished policy of insurance through which you were or might be the substance and the condition for which it was insured in any manner (for example, primary, pro-rata, or prescribed or fumished excess liability coverage or medical expense coverage) for 3.0 General Background Information-Business Entity the damages, claims, or actions that have arisen out of the x 3.1 Are you a corporation? If so, state: INCIDENT? If so, for each policy state: (a) the name stated in the current articles of incorporation; (a) the kind of coverage; b) all other names used by the corporation during the past (b) the name and ADDRESS of the insurance company; 10 years and the dates each was used; c) the name. ADDRESS, and telephone number of each (c) the date and place of incorporation; named insured; (d) the ADDRESS of the principal place of business; and (d) the policy number, (e) whether you are qualified to do business in California. x 3.2 Are you a partnership? If so, state: (e) the limits of coverage for each type of coverage con- tained in the policy. (a) the current partnership name (b) all other names used by the partnership during the past (1) whether any reservation of rights or controversy or 10 years and the dates each was used; coverage dispute exists between you and the insurance company, and (c) whether you are a limited partnership and, if so, under the laws of what jurisdiction; (g) the name. ADDRESS, and telephone number of the custodian of the policy. (d) the name and ADDRESS of each general partner, and 4.2 Are you self-insured under any statute for the damages, (e) the ADDRESS of the principal place of business. claims, or actions that have arisen out of the INCIDENT? If x 3.3 Are you a limited liability company? If so, state: so, specify the statute (a) the name stated in the current articles of organization; 5.0 /Reserved] (b) all other names used by the company during the past 10 6.0 Physical, Mental, or Emotional Injuries years and the date each was used; 6.1 Do you attribute any physical, mental, or emotional (c) the date and place of filing of the articles of organization; injuries to the INCIDENT? (If your answer is 'no, "do not (d) the ADDRESS of the principal place of business; and answer interrogatories 6.2 through 6.7) (e) whether you are qualmed to do business in California. 6.2 Identify each injury you attribute to the INCIDENT and the area of your body affected.DISC-001 6.3 Do you still have any complaints that you attribute to (c) state the amount of damage you are claiming for each the INCIDENT? If so, for each complaint state: item of property and how the amount was calculated; and (a) a description; (d) if the property was sold. state the name, ADDRESS, and (b) whether the complaint is subsiding, remaining the same. telephone number of the seller, the date of sale, and the or becoming worse; and sale price. (c) the frequency and duration. 6.4 Did you receive any consultation or examination 7.2 Has a written estimate or evaluation been made for any except from expert witnesses covered by Code of Civil item of property referred to in your answer to the preceding interrogatory? If so, for each estimate or evaluation state: Procedure sections 2034.210-2034.310) or treatment from a HEALTH CARE PROVIDER for any injury you attribute to (a) the name, ADDRESS, and telephone number of the the INCIDENT? If so, for each HEALTH CARE PROVIDER PERSON who prepared it and the date prepared; state: (b) the name, ADDRESS, and telephone number of each (a) the name, ADDRESS, and telephone number, PERSON who has a copy of it, and (b) the type of consultation, examination, or treatment (c) the amount of damage stated. provided; (c) the dates you received consultation, examination, or 7.3 Has any item of property referred to in your answer to treatment; and interrogatory 7.1 been repaired? If so, for each item state: (d) the charges to date. (a) the date repaired; 6.5 Have you taken any medication, prescribed or not, as a (b) a description of the repair, result of injuries that you attribute to the INCIDENT? If so. (c) the repair cost, for each medication state: (a) the name: )the name, ADDRESS, and telephone number of the PERSON who repaired it; and (b) the PERSON who prescribed or furnished it, (e) the name, ADDRESS, and telephone number of the (c) the date it was prescribed or fumished; PERSON who paid for the repair. (d) the dates you began and stopped taking it; and 8.0 Loss of Income or Earning Capacity (e) the cost to date 6.6 Are there any other medical services necessitated by the 8.1 Do you attribute any loss of income or earning capacity injuries that you attribute to the INCIDENT that were not to the INCIDENT? (If your answer is "no, " do not answer previously listed (for example, ambulance, nursing. interrogatories 8.2 through 8. 8J. prosthetics)? If so, for each service state: 8.2 State: (a) the nature: (a) the nature of your work; (b) the date; (b) your job title at the time of the INCIDENT; and (c) the cost, and (c) the date your employment began. (d) the name, ADDRESS, and telephone number 8.3 State the last date before the INCIDENT that you of each provider. worked for compensation. 6.7 Has any HEALTH CARE PROVIDER advised that you may require future or additional treatment for any injuries 8.4 State your monthly income at the time of the INCIDENT that you attribute to the INCIDENT? If so, for each injury and how the amount was calculated. state: 8.5 State the date you returned to work at each place of (a) the name and ADDRESS of each HEALTH CARE employment following the INCIDENT. PROVIDER; 8.6 State the dates you did not work and for which you lost [b) the complaints for which the treatment was advised; and income as a result of the INCIDENT. (c) the nature, duration, and estimated cost of the 8.7 State the total income you have lost to date as a result treatment. of the INCIDENT and how the amount was calculated. 7.0 Property Damage 8.8 Will you lose income in the future as a result of the | 7.1 Do you attribute any loss of or damage to a vehicle or INCIDENT? If so, state: other property to the INCIDENT? If so, for each item of (a) the facts on which you base this contention; property: (b) an estimate of the amount, (a) describe the property, (c) an estimate of how long you will be unable to work; and (b) describe the nature and location of the damage to the property: (d) how the claim for future income is calculated.9.0 Other Damages (c) the court, names of the parties, and case number of any action filed; 2.1 Are there any other damages that you attribute to the (d) the name, ADDRESS, and telephone number of any INCIDENT? If so, for each item of damage state: attorney representing you; (a) the nature; (e) whether the claim or action has been resolved or is (b) the date it occurred; pending; and ) a description of the injury. (c) the amount; and 11.2 In the past 10 years have you made a written claim or (d) the name, ADDRESS, and telephone number of each demand for workers' compensation benefits? If so, for each PERSON to whom an obligation was incurred. claim or demand state: 9.2 Do any DOCUMENTS support the existence or amount (a) the date, time, and place of the INCIDENT giving rise to of any item of damages claimed in interrogatory 9.1? If so, the claim; describe each document and state the name, ADDRESS. jb) the name, ADDRESS, and telephone number of your and telephone number of the PERSON who has each employer at the time of the injury. DOCUMENT. (c) the name, ADDRESS, and telephone number of the 10 0 Medical History workers' compensation insurer and the claim number; (d) the period of time during which you received workers" 10.1 At any time before the INCIDENT did you have com- compensation benefits; laints or injuries that involved the same part of your body claimed to have been injured in the INCIDENT? If so. for (e) a description of the injury: each state: (f) the name, ADDRESS, and telephone number of any HEALTH CARE PROVIDER who provided services; and (a) a description of the complaint or injury, (g) the case number at the Workers' Compensation (b) the dates it began and ended; and Appeals Board. (c) the name, ADDRESS, and telephone number of each HEALTH CARE PROVIDER whom you consulted or 12.0 Investigation-General who examined or treated you. 12.1 State the name, ADDRESS, and telephone number of 10.2 List all physical, mental, and emotional disabilities you each individual: had immediately before the INCIDENT. (You may omit (a) who witnessed the INCIDENT or the events occurring mental or emotional disabilities unless you attribute any immediately before or after the INCIDENT; mental or emotional injury to the INCIDENT. ) jb) who made any statement at the scene of the INCIDENT; 10.3 At any time after the INCIDENT, did you sustain (c) who heard any statements made about the INCIDENT injuries of the kind for which you are now claiming by any individual at the scene; and damages? If so, for each incident giving rise to an injury (d) who YOU OR ANYONE ACTING ON YOUR BEHALF state: claim has knowledge of the INCIDENT (except for (a) the date and the place it occurred; expert witnesses covered by Code of Civil Procedure section 2034). b) the name, ADDRESS, and telephone number of any other PERSON involved; 12.2 Have YOU OR ANYONE ACTING ON YOUR (c) the nature of any injuries you sustained; BEHALF interviewed any individual concerning the INCIDENT? If so. for each individual state: [d) the name, ADDRESS, and telephone number of each (a) the name, ADDRESS, and telephone number of the HEALTH CARE PROVIDER who you consulted or who individual interviewed; examined or treated you; and b) the date of the interview; and (e) the nature of the treatment and its duration. c) the name, ADDRESS, and telephone number of the PERSON who conducted the interview. 11.0 Other Claims and Previous Claims 12.3 Have YOU OR ANYONE ACTING ON YOUR 11.1 Except for this action, in the past 10 years have you BEHALF obtained a written or recorded statement from any filed an action or made a written claim or demand for individual concerning the INCIDENT? If so, for each compensation for your personal injuries? If so, for each statement state: action, claim, or demand state: (a) the name, ADDRESS, and telephone number of the (a) the date, time, and place and location (closest street individual from whom the statement was obtained; ADDRESS or intersection) of the INCIDENT giving rise jb) the name, ADDRESS, and telephone number of the to the action, claim, or demand; individual who obtained the statement; (b) the name, ADDRESS, and telephone number of each (c) the date the statement was obtained; and PERSON against whom the claim or demand was made (d) the name, ADDRESS, and telephone number of each or the action filed; PERSON who has the original statement or a copy.12.4 Do YOU OR ANYONE ACTING ON YOUR BEHALF 13.2 Has a written report been prepared on the now of any photographs, films, or videotapes depicting any surveillance? If so, for each written report state: place, object, or individual concerning the INCIDENT or (a) the title: plaintiff's injuries? If so, state: (b) the date: (a) the number of photographs or feet of film or videotape; (c) the name. ADDRESS, and telephone number of the (b) the places, objects, or persons photographed, filmed, or individual who prepared the report; and videotaped; (d) the name. ADDRESS, and telephone number of each (c) the date the photographs, films, or videotapes were PERSON who has the original or a copy. taken; 14 0 Statutory or Regulatory Violations 'd) the name, ADDRESS, and telephone number of the 14.1 Do YOU OR ANYONE ACTING ON YOUR BEHALF contend that any PERSON involved in the INCIDENT individual taking the photographs, films, or videotapes; violated any statute, ordinance, or regulation and that the and violation was a legal (proximate) cause of the INCIDENT? If (e) the name, ADDRESS, and telephone number of each so, identify the name, ADDRESS, and telephone number of PERSON who has the original or a copy of the each PERSON and the statute, ordinance, or regulation that photographs, films, or videotapes. was violated. 12.5 Do YOU OR ANYONE ACTING ON YOUR BEHALF 14.2 Was any PERSON cited or charged with a violation of know of any diagram, reproduction, or model of any place or any statute, ordinance, or regulation as a result of this thing (except for items developed by expert witnesses INCIDENT? If so, for each PERSON state: covered by Code of Civil Procedure sections 2034.210- a) the name. ADDRESS, and telephone number of the 2034.310) concerning the INCIDENT? If so, for each item PERSON; state: (b) the statute, ordinance, or regulation allegedly violated; (a) the type (i.e., diagram, reproduction, or model); c) whether the PERSON entered a plea in response to the jb) the subject matter, and citation or charge and, if so, the plea entered; and c) the name, ADDRESS, and telephone number of each (d) the name and ADDRESS of the court or administrative PERSON who has it. agency, names of the parties, and case number. 12.6 Was a report made by any PERSON concerning the 15.0 Denials and Special or Affirmative Defenses INCIDENT? If so, state: 15.1 Identify each denial of a material allegation and each (a) the name, title, identification number, and employer of special or affirmative defense in your pleadings, and for the PERSON who made the report; each: (b) the date and type of report made; a) state all facts on which you base the denial or special or affirmative defense; (c) the name, ADDRESS, and telephone number of the PERSON for whom the report was made; and b) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of those facts; (d) the name, ADDRESS, and telephone number of each and PERSON who has the original or a copy of the report. (c) identify all DOCUMENTS and other tangible things that 12.7 Have YOU OR ANYONE ACTING ON YOUR support your denial or special or affirmative defense, and BEHALF inspected the scene of the INCIDENT? If so, for state the name, ADDRESS, and telephone number of each inspection state: the PERSON who has each DOCUMENT. (a) the name, ADDRESS, and telephone number of the 16.0 Defendant's Contentions-Personal Injury individual making the inspection (except for expert 16.1 Do you contend that any PERSON, other than you or witnesses covered by Code of Civil Procedure plaintiff, contributed to the occurrence of the INCIDENT or sections 2034.210-2034.310); and the injuries or damages claimed by plaintiff? If so, for each (b) the date of the inspection. PERSON: 13.0 Investigation-Surveillance a) state the name, ADDRESS, and telephone number of 13.1 Have YOU OR ANYONE ACTING ON YOUR BEHALF the PERSON; conducted surveil ance of any individual involved in the b) state all facts on which you base your contention; INCIDENT or any party to this action? If so, for each sur- (c) state the names, ADDRESSES, and telephone numbers veillance state: of all PERSONS who have knowledge of the facts; and (a) the name, ADDRESS, and telephone number of the (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS. individual or party. and telephone number of the PERSON who has each b) the time, date, and place of the surveillance; DOCUMENT or thing c) the name, ADDRESS, and telephone number of the 16.2 Do you contend that plaintiff was not injured in the individual who conducted the surveillance; and INCIDENT? If so: 'd) the name, ADDRESS, and telephone number of each (a) state all facts on which you base your contention; PERSON who has the original or a copy of any b) state the names, ADDRESSES, and telephone numbers surveillance photograph, film, or videotape. 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.DISC-001 16.3 Do you contend that the injuries or the extent of the 1 16.8 Do you contend that any of the costs of repairing the injuries claimed by plaintiff as disclosed in discovery property damage claimed by plaintiff in discovery proceedings thus far in this case were not caused by the proceedings thus far in this case were unreasonable? If so: INCIDENT? If so, for each injury- (a) identify each cost item; (a) identify it; jb) state all facts on which you base your contention; (b) state all facts on which you base your contention; (c) state the names, ADDRESSES, and telephone numbers (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS. support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each and telephone number of the PERSON who has each DOCUMENT or thing- DOCUMENT or thing. 16.4 Do you contend that any of the services fumished by 18.0 Do YOU OR ANYONE ACTING ON YOUR BEHALF any HEALTH CARE PROVIDER claimed by plaintiff in have any DOCUMENT (for example, insurance bureau discovery proceedings thus far in this case were not due to index reports) concerning claims for personal injuries made the INCIDENT? If so: before or after the INCIDENT by a plaintiff in this case? If (a) identify each service; so, for each plaintiff state: (b) state all facts on which you base your contention; (a) the source of each DOCUMENT; (c) state the names, ADDRESSES, and telephone numbers (b) the date each claim arose; of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that (c) the nature of each claim; and support your contention and state the name, ADDRESS, 'd) the name, ADDRESS, and telephone number of the and telephone number of the PERSON who has each PERSON who has each DOCUMENT. DOCUMENT or thing- 16.10 Do YOU OR ANYONE ACTING ON YOUR BEHALF I16.5 Do you contend that any of the costs of services have any DOCUMENT concerning the past or present umished by any HEALTH CARE PROVIDER claimed as physical, mental, or emotional condition of any plaintiff in damages by plaintiff in discovery proceedings thus far in this case from a HEALTH CARE PROVIDER not previously this case were not necessary or unreasonable? If so: identified (except for expert witnesses covered by Code of (a) identify each cost, Civil Procedure sections 2034.210-2034.310)? If so, for b) state all facts on which you base your contention; each plaintiff state: c) state the names, ADDRESSES, and telephone numbers (a) the name, ADDRESS, and telephone number of each of all PERSONS who have knowledge of the facts; and HEALTH CARE PROVIDER; (d) identify all DOCUMENTS and other tangible things that b) a description of each DOCUMENT: and support your contention and state the name, ADDRESS, (c) the name, ADDRESS, and telephone number of the and telephone number of the PERSON who has each PERSON who has each DOCUMENT. DOCUMENT or thing. 17.0 Responses to Request for Admissions I 16.8 Do you contend that any part of the loss of earnings or income claimed by plaintiff in discovery proceedings thus far 17.1 Is your response to each request for admission served in this case was unreasonable or was not caused by the with these interrogatories an unqualified admission? If not, INCIDENT? If so: for each response that is not an unqualified admission: (a) identify each part of the loss; (a) state the number of the request; b) state all facts on which you base your contention; (b) state all facts on which you base your response; (c) state the names, ADDRESSES, and telephone numbers (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and of all PERSONS who have knowledge of those facts; (d) identify all DOCUMENTS and other tangible things that and support your contention and state the name, ADDRESS. (d) identify all DOCUMENTS and other tangible things that and telephone number of the PERSON who has each support your response and state the name, ADDRESS, DOCUMENT or thing- and telephone number of the PERSON who has each 16.7 Do you contend that any of the property damage DOCUMENT or thing. claimed by plaintiff in discovery Proceedings thus far in this 18.0 [Reserved] case was not caused by the INCIDENT? If so: (a) identify each item of property damage; 19.0 [Reserved] ibj state all facts on which you base your contention; 20_0 How the Incident Occurred-Motor Vehicle c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and 20.1 State the date, time, and place of the INCIDENT (closest street ADDRESS or intersection). 'd) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, 20.2 For each vehicle involved in the INCIDENT, state: and telephone number of the PERSON who has each (a) the year, make. model, and license number, DOCUMENT or thing. b) the name. ADDRESS, and telephone number of the Onver.DISC-001 (c) the name, ADDRESS, and telephone number of each (d) state the name, ADDRESS, and telephone number of occupant other than the driver, each PERSON who has custody of each defective part. d) the name, ADDRESS, and telephone number of each registered owner, 20.11 State the name, ADDRESS, and telephone number e) the name, ADDRESS, and telephone number of each of each owner and each PERSON who has had possession lessee: since the INCIDENT of each vehicle involved in the INCIDENT. if) the name, ADDRESS, and telephone number of each owner other than the registered owner or lien holder; 25.0 [Reserved] and 30.0 [Reserved] g) the name of each owner who gave permission or 40.0 [Reserved] consent to the driver to operate the vehicle. 20.3 State the ADDRESS and location where your trip 50.0 Contract began and the ADDRESS and location of your destination. 50.1 For each agreement alleged in the pleadings: 20.4 Describe the route that you followed from the (a) identify each DOCUMENT that is part of the agreement beginning of your trip to the location of the INCIDENT, and and for each state the name, ADDRESS, and telephone state the location of each stop. other than routine traffic number of each PERSON who has the DOCUMENT; stops, during the trip leading up to the INCIDENT. (b) state each part of the agreement not in writing. the 20.5 State the name of the street or roadway, the lane of name, ADDRESS, and telephone number of each travel, and the direction of travel of each vehicle involved in PERSON agreeing to that provision, and the date that the INCIDENT for the 500 feet of travel before the part of the agreement was made; INCIDENT. (c) identify all DOCUMENTS that evidence any part of the 20.6 Did the INCIDENT occur at an intersection? If so, agreement not in writing and for each state the name, describe all traffic control devices, signals, or signs at the ADDRESS, and telephone number of each PERSON intersection. who has the DOCUMENT; 20.7 Was there a traffic signal facing you at the time of the (d) identify all DOCUMENTS that are part of any INCIDENT? If so, state: modification to the agreement, and for each state the (a) your location when you first saw it, name, ADDRESS, and telephone number of each PERSON who has the DOCUMENT; b) the color, (e) state each modification not in writing. the date, and the (c) the number of seconds it had been that color, and name, ADDRESS, and telephone number of each 'd) whether the color changed between the time you first PERSON agreeing to the modification, and the date the saw it and the INCIDENT. modification was made; 20.8 State how the INCIDENT occurred, giving the speed, ) identify all DOCUMENTS that evidence any modification direction, and location of each vehicle involved: of the agreement not in writing and for each state the name, ADDRESS, and telephone number of each (a) just before the INCIDENT; PERSON who has the DOCUMENT. b) at the time of the INCIDENT; and c) just after the INCIDENT. 50.2 Was there a breach of any agreement alleged in the 20.0 Do you have information that a malfunction or defect in pleadings? If so, for each breach describe and give the date a vehicle caused the INCIDENT? If so: of every act or omission that you claim is the breach of the agreement a) identify the vehicle; 50.3 Was performance of any agreement alleged in the (b) identify each malfunction or defect, pleadings excused? If so, identify each agreement excused (c) state the name, ADDRESS, and telephone number of and state why performance was excused. each PERSON who is a witness to or has information about each malfunction or defect, and 50.4 Was any agreement alleged in the pleadings terminated by mutual agreement, release, accord and satisfaction, or 'd) state the name, ADDRESS, and telephone number of novation? If so, identify each agreement terminated, the date each PERSON who has custody of each defective part. of termination, and the basis of the termination. 20.10 Do you have information that any malfunction or 50.5 Is any agreement alleged in the pleadings unenforce- defect in a vehicle contributed to the injuries sustained in the able? If so, identify each unenforceable agreement and INCIDENT? If so: state why it is unenforceable. (a) identify the vehicle; 50.6 Is any agreement alleged in the pleadings ambiguous? b) identify each malfunction or defect, If so, identify each ambiguous agreement and state why it is ) state the name, ADDRESS, and telephone number of ambiguous. each PERSON who is a witness to or has information about each malfunction or defect; and 60.0 [Reserved]