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

Question 2.7 State: (a) the name and address of each school or other academic or vocational institution you have attended beginning with high school; (b) the dates you attended; (c) the highest grade level you have completed; (d) the degrees received. (Northern / Southern California Bike Accident Attorney - Author's note: This question is asked because the defense wants to know your educational history. This reflects on the issue of lost earnings, past, present and future).

Question 2.8 Have you ever been convicted of a felony? If so, for each conviction state: (a) the city and state where you were convicted; (b) the date of conviction; (c) the offense; (d) the court and case number. (Northern / Southern California Bike Accident Attorney - Author's note: This question is asked by your California motorcycle accident lawyer because if you have been convicted of a felony the defense can challenge your credibility as a witness by letting the jury know of this conviction.)

Question 2.9 Can you speak English with ease? If not, what language and dialect do you normally use? (Northern / Southern California Bike Accident Attorney - Author's note: This question is asked because the defense doesn't want you to later disavow your answers on the basis that you are not proficient in English. Also, they want to know if they need a court certified translator to translate for you at deposition or trial).

Question 2.10 Can you read and write English with ease? If not, what language and dialect do you normally use? (Northern / Southern California Bike Accident Attorney - Author's note: This question is asked by your California motorcycle accident lawyer because the defense will want you to review and sign your deposition when it is transcribed. They may also want you to review and testify certain documents they intend to introduce at trial. They don't want you to be able to say at trial that your language skills were insufficient to properly answer the question).

Question 2.11 At the time of the incident were you acting as an agent or employee for any person? If so, state: (a) the name, address, and telephone number of that person; (b) a description of your duties. (Northern / Southern California Bike Accident Attorney - Author's note: This question is asked because the defense wants to know (for purposes of a counter-suit) if you were acting on behalf of your employer or anyone else). For instance, in a motorcycle accident case the Plaintiff could have been a courier, in which case, the defendant might look to the employer of the Plaintiff for a counter suit if the defendant was injured in the accident.

Question 2.12 At the time of the incident did you or any other personal have any physical, emotional, or mental disability or condition that may have contributed to the occurrence of the incident? If so, for each person state: (a) the name, address, and telephone number; (b) the nature of the disability or condition; (c) the manner in which the disability or condition contributed to the occurrence of the incident. (Northern / Southern California Bike Accident Attorney - Author's note: This question is asked because the defense wants to know if the accident was the result of any condition you or some else might have had).

Question 2.13 Within 24 hours before the incident did you or any person involved in the incident use or take any of the following substance: alcoholic beverages, marijuana, or other drug or medication of any kind (prescription or not)? If so, for each person state: (a) the name, address, and telephone number; (b) the nature or description of each substance; (c) the quantity of each substance used or taken; (d) the date and time of day when each substance was used or taken; (e) the address where each substance was used or taken; (f) the name, address, and telephone number of each person who was present when each substance was used or taken; (g) the name, address, and telephone number of any health care provider that prescribed or furnished the substance and the condition of which it was prescribed or furnished. (Northern / Southern California Bike Accident Attorney - Author's note: This question is asked because the defense wants to know if alcohol or drugs were a contributing factor in the accident.