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

INTRODUCTORY COMMENT
In answering these Special Interrogatories, you are to furnish all information in the possession of your attorney, investigators, agents, employees, and all representatives.

The term INCIDENT includes the circumstances and events surrounding the alleged incident and/or injury, which gave, rise to this action or proceeding.

YOU or YOUR includes you, your agents, your employees, your insurance companies, their agents, their employees, your attorneys, your accountants, your investigators, and anyone else acting on your behalf.

The terms WRITING(S) or DOCUMENT(S) shall mean and refer to any writing as defined in evidence code section 250.

The subject ACCIDENT refers to the alleged incident, which is the subject of this action.

LOCATION OF THE ACCIDENT IN QUESTION means the precise point of impact of the ACCIDENT.

In answering these Special Interrogatories, you must make a diligent search of your records and all papers and materials in your possession and/or control.

This prologue preceded the following questions:
As to the owner of the property at the LOCATION OF THE ACCIDENT IN QUESTION (your attention is specifically drawn to the definition of this term as set forth in the prologue to these interrogatories, above) at the time of the ACCIDENT in question, please state the following:
1. The name of the owner

2. The address of the owner

3. How the owner took title (i.e. in what legal capacity

4. The date owner took title

5. Whether the property was leased or subleased to any tenant, and if so (answering questions six through nine):

6. The name of the tenant or sub tenant

7. The address of the tenant or sub tenant

8. The beginning date of the lease or sub lease

9. The ending date of the lease or sub lease