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

Question 16.6 Do you contend that any part of the loss of earnings or income claimed by Plaintiff in discovery proceedings thus for in this case was unreasonable or was not caused by the incident? If so: (a) identify each part of the loss; (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 t6hat support your contention and state the name, address, and telephone number of the person who has each document or thing. (As stated before, if you were in bike accident and seriously injured your hand preventing you from performing your normal job duties on a computer; the defense may have some theory or facts supporting a contention that the injury predated the accident; you will want to know what they contend and why.

Question 16.7 Do you contend that any of the property damage claimed by Plaintiff in discovery proceedings thus far in this case was not caused by the incident? If so: (a) identify each item of property damage; (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, addresses, and telephone number of the person who has each document or thing.

Question 16.8 Do you contend that any of the costs of repairing the property damage claimed by Plaintiff in discovery proceedings thus far in this case was unreasonable? If so: (a) identify each cost item; (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 things that support your contention and state the name, address, and telephone number of the person who has each document or thing.

Question 16.9 Do you or anyone acting on your behalf have any document (for example, insurance bureau index reports) concerning claims for personal injuries made before or after the incident by a Plaintiff in this case? If so, for each Plaintiff state: (a) the source of each document; (b) the date each claim arose; (c) the nature of each claim; (d) the name, address, and telephone number of the person who has each document.

Question 16.10 Do you or anyone acting on your behalf have any document concerning the past or present physical, mental;, or emotional condition of any Plaintiff in this case form a health care provider not previously identified (except for expert witnesses covered by the California Code of Civil Procedure? If so, for each Plaintiff state: (a) the name, address, and telephone number of each health care provider; (b) a description of each document; (c) the name, address, and telephone number of the person who has each document.

17.0 RESPONSES TO REQUEST FOR ADMISSIONS
The California / Sacramento bike accident lawyer poses the following:
Question 17.1 Is your response to each request for administration served with these interrogatories an unqualified admission? If not, for each response that is not an unqualified admission: (a) state the number of the request; (b) state all facts upon which you base your response; (c) state the names, addresses, and telephone numbers of all persons who have knowledge of those facts; (d) identify all documents and other tangible things that support your response and state the name, address, and telephone number of the person who has each document or thing. (Author's note: This question is asked because the defense wants to assure that your Responses to Request for Admissions is Unqualified and, if so, the extent and the basis for the qualification).

(18.0-19.0) RESERVED