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

5.0 RESERVED

6.0 PHYSICAL, MENTAL AND EMOTIONAL INJURIES
Question 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. (California personal injury attorney - Author's note: Question 6.1 to 6.7 are asked because the defense wants to know who treated you for such damages so they can get their records and take their deposition). For instance, you might be an avid motorcycle rider and are the victim of a motorcycle / bicycle accident. If you now have a fear of motorcycle riding, this would be a recoverable element of damages.

Question 6.2 Identify each injury you attribute to the incident and the area of your body affected.

Question 6.3 Do you still have any complaints that you attribute to the incident? If so, for each complaint state: (a) a description; (b) whether the complaint is subsiding, remaining the same, or becoming worse; (c) the frequency and duration.

Question 6.4 Did you receive any consultation or examination (except from expert witnesses covered by The California Code of Civil Procedure) or treatment from a Health Care Provider for any injury you attribute to the incident? If so, for each Health Care Provider state: (a) the name, address, and telephone number; (b) the type of consultation, examination, or treatment provided; (c) the dates you received consultation, examination, or treatment; (d) the charges to date.

Continuing, your California / Sacramento bike accident lawyer asks:
Question 6.5 Have you taken any medication, prescribed or not, as a result of injuries that you attribute to the incident? If so, for each mediation state: (a) the name; (b) the person who prescribed or furnished it; (c) the date prescribed or furnished it; (d) the dates you began and stopped taking it; (e) the cost to date.

Question 6.6 Are there any other medical services not previously listed (for example, ambulance, nursing, and prosthetics)? If so, for each service state: (a) the nature; (b) the date; (c) the cost; (d) the name, address, and telephone number of each provider.

Question 6.7 Has any Health Care Provider advised that you may require future or additional treatment for any injuries that you attribute to the incident? If so, for each injury state: (a) the name and address of each Health Care Provider; (b) the complaints for which the treatment was advised; (c) the nature, duration, and estimated cost of the treatment.

7.0 PROPERTY DAMAGE
Question 7.1 Do you attribute any loss of or damage to a vehicle or other property to the incident? If so, for each item or property: (a) describe the property; (b) describe the nature and location of the damage to the property; (c) state the amount of damage you are claiming for each item of property and how the amount was calculated; (d) if the property was sold, state the name, address, and telephone number of the seller, the date of sale, and the sale price. (California personal injury attorney - Author's note: Questions 7.1 to 7.3 are asked to determine how substantial the impact was [bearing on the issue of your physical injury] and how much the defense should pay you for your property damage).

Question 7.2 Has a written estimate or evaluation been made for any item of property referred to in your answer to the preceding interrogatory? If so, for each estimate or evaluation state: (a) the name, address, and telephone number of the person who prepared it and the date prepared; (b) the name, address, and telephone number of each person who has a copy; (c) the amount of damage stated. (Damages to any item of property is recoverable. For instance, if you have a motorcycle / bicycle accident, the damage to your motorcycle can be recovered.

Question 7.3 Has any item of property referred to in your answer to interrogatory 7.1 been repaired? If so, for each item state: (a) the date repaired; (b) a description of the repair; (c) the repair cost; (d) the name, address, and telephone number of the person who repaired it; (e) the name, address, and telephone number of the person who paid for the repair.