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

11.0 OTHER CLAIMS AND PREVIOUS CLAIMS
Question 11.1 Except for his action, in the last ten years have you filed an action or made a written claim or demand for compensation for your personal injuries? If so, for each action, claim, or demand state: (a) the date, time, and place and location of the incident (closest street address or intersection0; (b) the name, address, and telephone number of each person against whom the claim was made or action filed; (c) the name, address, and telephone number of any action filed; (d) the name, address, and telephone number of any attorney representing you; (e) weather the claim or action has been resolved or is pending. (Camarillo / Sacramento / Placerville Bike Accident Lawyer - Author's note: Questions 11.1 and 11.2 are asked because the defense wants to know all prior claims filed by you. This relates to the issue of whether you are claiming injury based upon an older injury. Also, the defense is entitled to review any depositions or trial transcripts from your earlier case.)

Question 11.2 In the last ten years have you made a written claim or demand for worker's compensation benefits? If so, for each claim or demand state: (a) the date, time, and place of the incident giving rise to the claim; (b) the name address, and telephone number of your employer at the time of the injury; (c) the name, address, and telephone number of the workers compensation insurer and the claim number; (d) the period of time during which you received worker's compensation benefits; (e) a description of the injury; (f) the name, address, and telephone number of any Health Care Provider that provided services; (g) the case number at the Worker's Compensation Appeals Board.

12.0 INVESTIGATION - GENERAL
The motorcycle accident lawyer then asks:
Question 12.1 State the name, address, and telephone number of each individual: (a) who witnessed the incident or the events occurring immediately before or after the incident; (b) Who made any statement at the scene of the incident; (c) who heard any statements made about the incident by any individual at the scene; (d) who you or anyone acting on your behalf claim has knowledge of the incident (except for expert witnesses covered by The California Code of Civil Procedure (Camarillo / Sacramento / Placerville Bike Accident Lawyer - Author's note: Questions 12.1 to 12.7 are asked because the defense wants to factually prepare it's case for trial and does not want to be surprised by any witnesses you may introduce at trial).

Question 12.2 Have you or anyone acting on your behalf interviewed any individual concerning the incident? If so for each individual state: (a) the name, address, and telephone number of the individual interviewed; (b) the date of the interview; (c) the name, address, and telephone number of he person who conducted interview. (For instance, if someone witnessed a motorcycle accident, you would want to have this person as a witness.)

Question 12.3 Have you or anyone acting on your behalf obtained a written or recorded statement from any individual concerning the incident? If so, for each statement state: (a) the name, address, and telephone number of the individual from whom the statement was obtained; (b) the name, address, and telephone number of the individual who obtained the statement; (c) the date the statement was obtained; (d) the name, address, and telephone number of each person who has the original statement or a copy.

Question 12.4 Do you or anyone acting on your behalf know of any photographs, films, or videotapes depicting any place, object, or individual concerning the incident or Plaintiff's injuries? If so, state: (a) the number of photographs or feet of film or videotape; (b) the places, objects, or persons photographed, filmed, or videotaped; (c) the date the photographs, films, or videotapes were taken; (d) the name, address, and telephone number of the individual taking the photographs, films, or videotapes; (e) the name, address, and telephone number of each person who has the original or a copy.