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

Question 12.5 Do you or anyone acting on your behalf know of any diagram, reproduction, or model of any place or thing (except for items developed by expert witnesses covered by code of California Code of Civil Procedure concerning the incident? If so, for each item state: (a) the type (i.e., diagram, reproduction, or model); (b) the subject matter; (c) the name, address, and telephone number of each person who has it.

Question 12.6 Was a report made by any person concerning the incident? If so, state: (a) the name, title, identification number, and employer of the person who made the report; (b) the date and type of report made; (c) the name, address, and telephone number of the person for whom the report was made.

Question 12.7 Have you or anyone acting on your behalf inspected the scene of the incident? If so, for each inspection state: (a) the name, address, and telephone number of the individual making the inspection (except for expert witnesses covered by the California Code of Civil Procedure; (b) the date of the inspection.

13.0 INVESTIGATION - SURVEILLANCE
Question 13.1 Have you or anyone acting on your behalf conducted surveillance of any individual in the incident or any part to this action? So for each surveillance state: (a) the name, address, and telephone number of the individual or party; (b) the time, date, and place of the surveillance; (c) the name, address, and telephone number of the individual who conducted the surveillance. (Camarillo / Sacramento / Placerville Bike Accident Lawyer - Author's note: Questions 13.1 and 13.2 are asked to discover defense surveillance. Sometimes, in larger cases, the defense will hire a private investigator, attempting to videotape you engaging in an activity [such as washing your car or doing heavy lifting] that indicates your injuries are not as severe as alleged).

Question 13.2 Has a written report been prepared on the surveillance? If so, for each written report state: (a) the title; (b) the date; (c) the name, address, and telephone number of the individual who prepared the report; (d) the name, address, and telephone number of each person who has the original or a copy.

14.0 STATUTORY OR REGULATORY VIOLATIONS
Question 14.1 Do you or anyone acting on your behalf contend that any person involved in the incident violated any statute, ordinance, or regulation and that the violation was a legal (proximate) cause of the incident? If so, identify each person and the statute, ordinance, or regulation. (Camarillo / Sacramento / Placerville Bike Accident Lawyer - Author's note: Questions 14.1 and 14.2 are asked because the defense wants to know all evidence of statutory violation. A violation of the vehicle code by one party in an accident code can be used as strong evidence that they were partially or totally responsible for the accident. For instance, if you were in a motorcycle accident and were riding on the sidewalk in violation of a statute, the defense would want to use this).

The motorcycle accident lawyer will want to know the following:
Question 14.2 Was any person cited or charged with a violation of any statue, ordinance, or regulation as a result of this incident? If so, for each person state: (a) the name, address, and telephone number of the person; (b) the statute, ordinance, or regulation allegedly violated; (c) whether the person entered a plea in response to the citation or charge and, if so, the plea entered; (d) the name and address of the court or administrative agency, names of the parties and case number.