California Personal Injury and Bike Accident Attorney - Discovery; Written Interrogatories

FORM INTERROGATORIES

1.0 IDENTITY OF PERSONS ANSWERING THESE INTERROGATORIES
Question 1.1 State the name, address, telephone number, and relationship to you of each person who prepared or assisted in the preparation of the responses to these interrogatories. (Do not identify anyone who simply typed or reproduced the responses.) (Northern / Southern California Bike Accident Lawyer - Author's note: This question is asked because the defense wants to know if anyone else assisted you in the preparation so, if necessary, they can subpoena that person for deposition or trial).

2.0 GENERAL BACKGROUND INFORMATION - INDIVIDUAL

Question 2.1 State (a) your name; (b) every name you have used in the past; (c) the dates you sued each name. (Northern / Southern California Bike Accident Attorney - Author's note: This question is asked because the defense wants to check on any prior law suits you have filed, and generally run an information check if necessary).

Question 2.2 State the date and place of your birth. (Northern / Southern California Bike Accident Attorney - Author's note: This question is asked because the defense wants to check on any prior law suits you have filed, and generally run an information check if necessary).

Question 2.3 At the time of the incident, did you have a driver's license? If so state: (a) the state or other issuing entity; (b) the license number and type; (c) the date of issuance; (d) all restrictions. (Northern / Southern California Bike Accident Attorney - Author's note: This question is asked because the defense wants to check your driving record; if the plaintiff was injured, for instance, in a motorcycle / bicycle accident, the defendant is still entitled to see the plaintiff's driver's license, if for nothing else, for general identification).

Question 2.4 At the time of the incident, did you have any other permit or license for the operation of a motor vehicle? If so, state: (a) the state or other issuing entity; (b) the license number and type; (c) the date of issuance; (d) all restrictions. (This question is asked because the defense wants to check your driving record).

Question 2.5 State: (a) your present residence address; (b) your residence addresses for the last five years; (c) the dates you lived at each address. (Northern / Southern California Bike Accident Attorney - Author's note: This question is asked because the defense wants to check on any prior law suits you have filed, and generally run an information check if necessary).

Question 2.6 State: (a) the name, address, and telephone number of your present employer or place of self-employment; (b) the name, address, dates of employment, job title and nature of work for each employment you have had from five years before the incident until today. (Northern / Southern California Bike Accident Lawyer - Author's note: This question is asked because the defense wants to know your employment history. This reflects on the issue of lost earnings, past, present and future).