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

8.0 LOSS OF INCOME OR EARNING CAPACITY
Your Southern / Northern California bike accident attorney then asks:
Question 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. (Camarillo / Sacramento / Placerville Bike Accident Lawyer - Author's note: Question 8.1 to 8.8 are asked because the defense wants to know on what basis you claim lost income, past present and future).

Question 8.2 State: (a) the nature of your work; (b) your job title at the time of the incident; (c) the date your employment began.

Question 8.3 State the last date before the incident that you worked for compensation.

Question 8.4 State your monthly income at the time of the incident and how the amount was calculated.

Question 8.5 State the date you retuned to work at each place of employment following the incident.

Question 8.6 State the dates you did not work and for which you lost income.

Question 8.7 State the total income you have lost to date as a result of the incident and how the amount was calculated.

Question 8.8 Will you lose income in the future as a result of the incident? If so, state: (a) the facts upon which you base this contention; (b) an estimate of the amount; (c) an estimate of how long you will be unable to work; (d) how the claim for future income is calculate. (For instance, assume you have had a motorcycle accident and permanently damaged the nerves in your right hand. You work at a computer eight hours a day and now you can no longer use a keyboard. This loss of future income must be calculated.

9.0 OTHER DAMAGES
Question 9.1 Are there any other damages that you attribute to the incident? If so, for each item of damage state: (a) the nature; (b) the date it occurred; (c) the amount; (d) the name, address, and telephone number of each person to whom an obligation was incurred. (Camarillo / Sacramento / Placerville Bike Accident Lawyer - Author's note: Question 9.1 and 9.2 are asked because the defense wants to know if you claim any other damages and your basis of calculation).

Question 9.2 Do any documents support the existence or amount of any item of damages claimed in interrogatory 9.1? If so, state the name, address, and telephone number of the person who has each document.

10.0 MEDICAL HISTORY
Question 10.1 At any time before the incident did you have complaints or injuries that involved the same part of your body claimed to have been injured in the incident? If so, for each state: (a) a description; (b) the dates it began and ended; (c) the name, address, and telephone number of each Health Care Provider whom you consulted or who examined or treated you. (Camarillo / Sacramento / Placerville Bike Accident Lawyer - Author's note: Question 10.1 through 10.3 are asked because you have put your medical condition in issue and the defense wants to familiarize itself with your medical condition, past, present and future. Your medical records are "privileged." This generally means others may not seek medical records from your doctor. This privilege is waived when you put your physical condition in issue ).

The motorcycle accident lawyer probes further:
Question 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. As in the above example, if you were in a motorcycle accident, were an avid motorcycle rider and now can no longer enjoy the activity for fear of riding a motorcycle, this would be recoverable.)

10.3 At any time after the incident, did you sustain injuries of the kind for which you are now claiming damages. If so, for each incident state: (a) the date and the place it occurred; (b) the name, address, and telephone number of any other person involved; (c) the nature of any injuries you sustained; (d) the name, address, and telephone number of each Health Care Provider that you consulted or who examined or treated you; (e) the nature of the treatment and it's duration.