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

15.0 SPECIAL OR AFFIRMATIVE DEFENSES
Question 15.1 Identify each denial of a material allegation and each special or affirmative defense in your pleadings and of reach: (a) state all facts upon which you base the denial or special or affirmative defense; (b) state the names, addresses, and telephone numbers of all persons who have knowledge of those facts; (c) identify all documents and other tangible things which support your denial or special or affirmative defense, and state the name, address, and telephone number of the person who has each document. (Camarillo / Sacramento / Placerville Bike Accident Lawyer - Author's note: This question is normally directed to the defense. It is asked because the defense will always have pled something called "Affirmative Defenses." These are defenses that, if proven, can absolve the Defendant from some or all liability.)

16.0 DEFENDANT'S CONTENTIONS - PERSONAL INJURY
Question 16.1 Do you contend that any person, other than you or Plaintiff, contributed to the occurrence of the incident or the injuries or damages claimed by Plaintiff? If so, for each person: (a) state the name, address, and telephone number of the person. (b) state all facts upon which you base your contention; (c) state the names, addresses, and telephone number of all persons who have knowledge of the facts; (d) identify all documents and other tangible things that support your contention and state the name, address, and telephone number of the person who has each document or thing. (Camarillo / Sacramento / Placerville Bike Accident Lawyer - Author's note: Plaintiff usually asks Questions 16.1 to 16.10. They are used to gather more facts and contentions that may be raised by Defendant at trial. For instance if you were in a motorcycle accident and contended that the manufacturer was partially at fault, the defense would be entitled to this).

Question 16.2 Do you contend that Plaintiff was not injured in the incident? If so: (a) state all facts upon which you base your contention; (b) state the names, addresses, and telephone numbers of all persons who have knowledge of the facts; (c) identify all documents and other tangible things that support your contention and state the name, address and telephone number of the person who has each document or thing.

Question 16.3 Do you contend that the injuries or the extent of the injuries claimed by Plaintiff as disclosed in discovery proceedings thus far in this case were not caused by the incident? If so, for each injury: (a) identify it; (b) state all facts upon which you base your contention; (c) state the names, addresses, and telephone numbers of all persons who have knowledge of the facts; (d) identify all documents and other tangible things that support your contention and state the name, address, and telephone number of the person who has each document or thing.

Question 16.4 Do you contend that any of the services furnished by any health care provider claimed by Plaintiff in discovery proceedings thus far in this case were not due to the incident? If so: (a) identify each service; (b) state all facts upon which you base your contention; (c) state the names, addresses, and telephone numbers of all persons who have knowledge of the facts; (d) identify all documents and other tangible things that support your contention and state the name, address, and telephone number of the person who has each document or thing.

Your California / Sacramento bike accident lawyer follows up with:
Question 16.5 Do you contend that any of the costs of services furnished by any health care provider claimed as damages by Plaintiff in discovery proceedings thus far in this case were unreasonable? If so: (a) identify each cost; (b) state all facts upon which you base your contention; (c) state the names, addresses, and telephone numbers of all persons who have knowledge of the facts; (d) identify all documents and other tangible things that support your contention and state the name, address, and telephone number of the person who has each document or thing.