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FORM INTERROGATORIESEMPLOYMENT LAW: DISC-002 (California)

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DISC-002
Sec. 2. Instructions to the Asking Party
I declare under penalty of perjury under the laws of the State of
California that the foregoing answers are true and correct.
Additional interrogatories may be attached.
Sec. 3. Instructions to the Answering Party
Page 1 of 8
Sec. 1. Instructions to All Parties
Interrogatories are written questions prepared by a party to an
action that are sent to any other party in the action to be
answered under oath. The interrogatories below are form
interrogatories approved for use in employment cases.
For time limitations, requirements for service on other parties,
and other details, see Code of Civil Procedure sections
2030.010–2030.410 and the cases construing those sections.
(b)
These form interrogatories do not change existing law relating
to interrogatories nor do they affect an answering party’s right
to assert any privilege or make any objection.
(c)
These form interrogatories are designed for optional use by
parties in employment cases. (Separate sets of
interrogatories, Form Interrogatories—General (form
DISC-001) and Form Interrogatories—Limited Civil Cases
(Economic Litigation) (form DISC-004) may also be used
where applicable in employment cases.)
Insert the names of the EMPLOYEE and EMPLOYER to
whom these interrogatories apply in the definitions in sections
4(d) and (e) below.
Check the box next to each interrogatory that you want the
answering party to answer. Use care in choosing those
interrogatories that are applicable to the case.
The interrogatories in section 211.0, Loss of Income
Interrogatories to Employer, should not be used until the
employer has had a reasonable opportunity to conduct an
investigation or discovery of the employee’s injuries and
damages.
You must answer or provide another appropriate response to
each interrogatory that has been checked below.
As a general rule, within 30 days after you are served with
these interrogatories, you must serve your responses on the
asking party and serve copies of your responses on all other
parties to the action who have appeared. See Code of Civil
Procedure sections 2030.260–2030.270 for details.
Each answer must be as complete and straightforward as the
information reasonably available to you permits. If an
interrogatory cannot be answered completely, answer it to the
extent possible.
If you do not have enough personal knowledge to fully answer
an interrogatory, say so, but make a reasonable and good
faith effort to get the information by asking other persons or
organizations, unless the information is equally available to
the asking party.
Whenever an interrogatory may be answered by referring to a
document, the document may be attached as an exhibit to the
response and referred to in the response. If the document has
more than one page, refer to the page and section where the
answer to the interrogatory can be found.
Whenever an address and telephone number for the same
person are requested in more than one interrogatory, you are
required to furnish them in answering only the first
interrogatory asking for that information.
If you are asserting a privilege or making an objection to an
interrogatory, you must specifically assert the privilege or
state the objection in your written response.
Your answers to these interrogatories must be verified, dated,
and signed. You may wish to use the following form at the end
of your answers:
Sec. 4. Definitions
Words in BOLDFACE CAPITALS in these interrogatories are
defined as follows:
PERSON includes a natural person, firm, association,
organization, partnership, business, trust, limited liability
company, corporation, or public entity.
FORM INTERROGATORIES—EMPLOYMENT LAW
Asking Party:
Answering Party:
Set No.:
CASE NUMBER:
SUPERIOR COURT OF CALIFORNIA, COUNTY OF
SHORT TITLE OF CASE:
TELEPHONE NO.:
FAX NO. (Optional):
E-MAIL ADDRESS (Optional):
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
ATTORNEY FOR (Name):
Code of Civil Procedure, §§
2030.010–2030.410, 2033.710
www.courts.ca.gov
FORM INTERROGATORIES–EMPLOYMENT LAW
Form Approved for Optional Use
Judicial Council of California
DISC-002 [Rev. January 1, 2009]
(a)
(b)
(c)
(a)
(d)
(e)
(b)
(a)
(c)
(d)
(e)
(f)
(g)
(h)
(SIGNATURE)
(a)
(Date)
(b) YOU OR ANYONE ACTING ON YOUR BEHALF 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.
CONTENTS
200.0 Contract Formation
(c) EMPLOYMENT means a relationship in which an
EMPLOYEE provides services requested by or on behalf of
an EMPLOYER, other than an independent contractor
relationship.
201.0 Adverse Employment Action
202.0 Discrimination Interrogatories to Employee
203.0 Harassment Interrogatories to Employee
204.0 Disability Discrimination
(d)
205.0 Discharge in Violation of Public Policy
206.0 Defamation
207.0 Internal Complaints
208.0 Governmental Complaints
(If no name is inserted, EMPLOYEE means all such
PERSONS.)
210.0 Loss of income Interrogatories to Employee
211.0 Loss of income Interrogatories to Employer
(e)
212.0 Physical, Mental, or Emotional Injuries—Interrogatories to
Employee
213.0 Other Damages Interrogatories to Employee
214.0 Insurance
215.0 Investigation
(If no name is inserted, EMPLOYER means all such
PERSONS.)
216.0 Denials and Special or Affirmative Defenses
217.0 Response to Request for Admissions
(f)
ADVERSE EMPLOYMENT ACTION means any
TERMINATION, suspension, demotion, reprimand, loss of
pay, failure or refusal to hire, failure or refusal to promote, or
other action or failure to act that adversely affects the
EMPLOYEE’S rights or interests and which is alleged in the
PLEADINGS .
200.0 Contract Formation
state all facts upon which you base this contention;
(g) TERMINATION means the actual or constructive termination
of employment and includes a discharge, firing, layoff,
resignation, or completion of the term of the employment
agreement.
(h) PUBLISH means to communicate orally or in writing to
anyone other than the plaintiff. This includes communications
by one of the defendant’s employees to others. (Kelly v.
General Telephone Co. (1982) 136 Cal.App.3d 278, 284.)
identify all DOCUMENTS that support your contention.
(i) PLEADINGS means the original or most recent amended
version of any complaint, answer, cross-complaint, or answer
to cross-complaint.
state all facts upon which you base this contention;
(j)
BENEFIT means any benefit from an EMPLOYER, including
an “employee welfare benefit plan” or employee pension
benefit plan” within the meaning of Title 29 United States
Code section 1002(1) or (2) or ERISA.
identify all DOCUMENTS that support your contention.
(k) HEALTH CARE PROVIDER includes any PERSON referred
to in Code of Civil Procedure section 667.7(e)(3).
(l) DOCUMENT means a writing, as defined in Evidence Code
section 250, and includes the original or a copy of
handwriting, typewriting, printing, photostats, photographs,
electronically stored information, and every other means of
recording upon any tangible thing and form of communicating
or representation, including letters, words, pictures, sounds,
or symbols, or combinations of them.
state all facts upon which you base this contention;
(m) ADDRESS means the street address, including the city, state,
and zip code.
identify all DOCUMENTS that support your contention.
DISC-002 [Rev. January 1, 2009]
FORM INTERROGATORIES–EMPLOYMENT LAW
Page 2 of 8
Sec. 5. Interrogatories
The following interrogatories for employment law cases have
been approved by the Judicial Council under Code of Civil
Procedure section 2033.710:
209.0 Other Employment Claims by Employee or Against
Employer
state the name, ADDRESS, and telephone number of
each PERSON who has knowledge of those facts; and
state the name, ADDRESS, and telephone number of
each PERSON who has knowledge of those facts; and
state the name, ADDRESS, and telephone number of
each PERSON who has knowledge of those facts; and
DISC-002
EMPLOYEE means a PERSON who provides services in an
EMPLOYMENT relationship and who is a party to this lawsuit.
For purposes of these interrogatories, EMPLOYEE refers to
(insert name):
EMPLOYER means a PERSON who employs an
EMPLOYEE to provide services in an EMPLOYMENT
relationship and who is a party to this lawsuit. For purposes
of these interrogatories, EMPLOYER refers to (insert name):
(a)
(a)
(b)
(c)
200.1 Do you contend that the EMPLOYMENT relationship
was at “at will”? If so:
200.2 Do you contend that the EMPLOYMENT relationship
was not “at will”? If so:
200.3 Do you contend that the EMPLOYMENT relationship
was governed by any agreement—written, oral, or implied?
If so:
(b)
(c)
(a)
(b)
(c)
state the specific facts;
state when and how EMPLOYER first learned of each
specific fact;
state the manner, if any, in which employees
acknowledged either receipt of the DOCUMENT or
knowledge of its contents.
If so, for each action, provide the following:
all reasons for each ADVERSE EMPLOYMENT
ACTION;
the identity of all DOCUMENTS relied upon in making
each ADVERSE EMPLOYMENT ACTION decision.
which parts of the collective bargaining agreement or
memorandum of understanding, if any, govern (1) any
dispute or claim referred to in the PLEADINGS and (2)
the rules or procedures for resolving any dispute or
claim referred to in the PLEADINGS .
state the names of the parties to the relationship;
state all facts upon which you base your contention
that the parties were in a relationship other than an
EMPLOYMENT relationship.
identify the ADVERSE EMPLOYMENT ACTION;
201.0 Adverse Employment Action
identify any rules, guidelines, policies, or procedures
that were used to evaluate the EMPLOYEE’S specific
job performance;
state all reasons for the EMPLOYEE’S
TERMINATION;
state the name, ADDRESS, and telephone number of
each PERSON who participated in the TERMINATION
decision;
state the names, ADDRESSES, and telephone
numbers of all PERSONS who have knowledge of the
EMPLOYEE'S specific job performance that played a
role in that ADVERSE EMPLOYMENT ACTION; and
state the name, ADDRESS, and telephone number of
each PERSON who provided any information relied
upon in the TERMINATION decision; and
describe all warnings given with respect to the
EMPLOYEE’S specific job performance.
Page 3 of 8
DISC-002 [Rev. January 1, 2009]
FORM INTERROGATORIES–EMPLOYMENT LAW
state the date and title of the DOCUMENT and a
general description of its contents;
state the manner in which the DOCUMENT was
communicated to employees; and
the names and ADDRESSES of the parties to the
collective bargaining agreement or memorandum of
understanding;
the beginning and ending dates, if applicable, of the
collective bargaining agreement or memorandum of
understanding; and
identify the relationship; and
identify all DOCUMENTS relied upon in the
TERMINATION decision.
state the name, ADDRESS, and telephone number of
each PERSON who has knowledge of the specific facts;
and
identify all DOCUMENTS that evidence these specific
facts.
the name, ADDRESS, and telephone number of each
PERSON who participated in making each ADVERSE
EMPLOYMENT ACTION decision;
the name, ADDRESS, and telephone number of each
PERSON who provided any information relied upon in
making each ADVERSE EMPLOYMENT ACTION
decision; and
identify the EMPLOYEE'S specific job performance that
played a role in that ADVERSE EMPLOYMENT
ACTION;
state the names, ADDRESSES, and telephone
numbers of all PERSONS who had responsibility for
evaluating the specific job performance of the
EMPLOYEE;
DISC-002
200.4 Was any part of the parties’ EMPLOYMENT
relationship governed in whole or in part by any written
rules, guidelines, policies, or procedures established by the
EMPLOYER? If so, for each DOCUMENT containing the
written rules, guidelines, policies, or procedures:
(a)
(b)
(c)
200.5 Was any part of the parties’ EMPLOYMENT
relationship covered by one or more collective bargaining
agreements or memorandums of understanding between
the EMPLOYER (or an association of employers) and any
labor union or employee association? If so, for each
collective bargaining agreement or memorandum of
understanding, state:
(a)
(b)
(c)
200.6 Do you contend that the EMPLOYEE and the
EMPLOYER were in a business relationship other than an
EMPLOYMENT relationship? If so, for each relationship:
(a)
(b)
(c)
201.1 Was the EMPLOYEE involved in a TERMINATION?
If so:
(a)
(b)
(c)
(d)
201.2 Are there any facts that would support the
EMPLOYEE’S TERMINATION that were first discovered
after the TERMINATION? If so:
201.3 Were there any other ADVERSE EMPLOYMENT
ACTIONS, including (the asking party should list the
ADVERSE EMPLOYMENT ACTIONS):
(a)
(b)
(c)
(d)
(a)
(b)
(c)
(d)
(b)
(d)
(e)
(f)
(g)
(a)
201.4 Was the TERMINATION or any other ADVERSE
EMPLOYMENT ACTIONS referred to in Interrogatories
201.1 through 201.3 based in whole or in part on the
EMPLOYEE'S job performance? If so, for each action:
(c)
identify all DOCUMENTS evidencing those facts.
204.0 Disability Discrimination
state the PERSON’S name, job title, ADDRESS, and
telephone number;
identify the duties; and
state the date on which the PERSON started to
perform the duties.
the nature of such injury or illness;
whether EMPLOYEE has filed or applied for disability
benefits of any type. If so, state the date, identify the
nature of the benefits applied for, and the outcome of
any such application.
202.0 Discrimination—Interrogatories to Employee
state the name, ADDRESS, and telephone number of
each PERSON with knowledge of those facts; and
identify each DOCUMENT that refers to the
communications.
203.0 Harassment—Interrogatories to Employee
state the name, ADDRESS, telephone number, and
employment position of each PERSON whom you
contend harassed you;
for each PERSON whom you contend harassed you,
describe the harassment;
FORM INTERROGATORIES–EMPLOYMENT LAW
Page 4 of 8
DISC-002 [Rev. January 1, 2009]
identify each ADVERSE EMPLOYMENT ACTION that
involved unlawful discrimination;
identify each characteristic (for example, gender, race,
age, etc.) on which you base your claim or claims of
discrimination;
state all facts upon which you base each claim of
discrimination;
identify all DOCUMENTS evidencing those facts.
identify each characteristic (for example, gender, race,
age, etc.) on which you base your claim of harassment;
state all facts upon which you base your contention that
you were unlawfully harassed;
state the name, ADDRESS, and telephone number of
each PERSON with knowledge of those facts; and
how such injury or illness occurred;
the date on which such injury or illness occurred;
whether EMPLOYEE has filed a workers’
compensation claim. If so, state the date and outcome
of the claim; and
state the name, ADDRESS, and telephone number of
each person who made or received the
communications;
state the name, ADDRESS, and telephone number of
each PERSON who witnessed the communications;
describe the date and substance of the
communications; and
DISC-002
201.5 Was any PERSON hired to replace the EMPLOYEE
after the EMPLOYEE’S TERMINATION or demotion? If so,
state the PERSON'S name, job title, qualifications,
ADDRESS and telephone number, and the date the
PERSON was hired.
201.6 Has any PERSON performed any of the
EMPLOYEE’S former job duties after the EMPLOYEE’S
TERMINATION or demotion? If so:
(b)
(a)
(c)
201.7 If the ADVERSE EMPLOYMENT ACTION involved
the failure or refusal to select the EMPLOYEE (for
example, for hire, promotion, transfer, or training), was any
other PERSON selected instead? If so, for each ADVERSE
EMPLOYMENT ACTION, state the name, ADDRESS, and
telephone number of each PERSON selected; the date the
PERSON was selected; and the reason the PERSON was
selected instead of the EMPLOYEE .
202.1 Do you contend that any ADVERSE
EMPLOYMENT ACTIONS against you were
discriminatory? If so:
(b)
(d)
(e)
(a)
(c)
202.2 State all facts upon which you base your contention
that you were qualified to perform any job which you
contend was denied to you on account of unlawful
discrimination.
203.1Do you contend that you were unlawfully harassed in
your employment? If so:
(b)
(a)
(d)
(e)
(f)
(c)
204.1 Name and describe each disability alleged in the
PLEADINGS .
204.2 Does the EMPLOYEE allege any injury or illness
that arose out of or in the course of EMPLOYMENT? If
so, state:
(b)
(d)
(e)
(a)
(c)
204.3 Were there any communications between the
EMPLOYEE (or the EMPLOYEE’S HEALTH CARE
PROVIDER) and the EMPLOYER about the type or extent
of any disability of EMPLOYEE? If so:
(b)
(d)
(a)
(c)
204.4 Did the EMPLOYER have any information about the
type, existence, or extent of any disability of EMPLOYEE
other than from communications with the EMPLOYEE or the
EMPLOYEE’S HEALTH CARE PROVIDER? If so, state the
sources and substance of that information and the name,
ADDRESS, and telephone number of each PERSON who
provided or received the information.
204.5 Did the EMPLOYEE need any accommodation to
perform any function of the EMPLOYEE’S job position or
need a transfer to another position as an accommodation? If
so, describe the accommodations needed.
state whether, at the time the statement was
PUBLISHED, the PERSON who PUBLISHED the
statement believed it to be true; and
state all facts upon which the PERSON who published
the statement based the belief that it was true.
identify each DOCUMENT that refers to the
communication.
207.0 Internal Complaints
describe the accommodation considered;
state whether the accommodation was offered to the
EMPLOYEE;
state the EMPLOYEE’S response; or
state the title and date of each DOCUMENT containing
the policies or regulations and a general description of
the DOCUMENT’S contents;
205.0 Discharge in Violation of Public Policy
state, if you contend that the EMPLOYEE’S failure to
use internal complaint procedures was excused, all
facts why the EMPLOYEE’S use of the procedures was
excused.
state all facts upon which you base your contention
that the EMPLOYER violated public policy.
state the date of the complaint;
206.0 Defamation
state the name, ADDRESS, telephone number, and job
title of each PERSON who participated in making
decisions about how to conduct the investigation;
state the name, ADDRESS, and telephone number of
each person to whom the statement was
PUBLISHED;
Page 5 of 8
DISC-002 [Rev. January 1, 2009]
FORM INTERROGATORIES–EMPLOYMENT LAW
state the name, ADDRESS, and telephone number of
each PERSON who made or received the
communication;
state the name, ADDRESS, and telephone number of
each PERSON who witnessed the communication;
describe the date and substance of the communication;
and
if the accommodation was not offered, state all the
reasons why this decision was made;
state the name, ADDRESS, and telephone number of
each PERSON who on behalf of EMPLOYER made
any decision about what accommodations, if any, to
make for the EMPLOYEE; and
state the name, ADDRESS, and telephone number of
each PERSON who on behalf of the EMPLOYER
made or received any communications about what
accommodations, if any, to make for the EMPLOYEE .
identify the constitutional provision, statute, regulation,
or other source of the public policy that you contend
was violated; and
identify the PUBLISHED statement;
state the name, ADDRESS, telephone number, and
job title of each person who PUBLISHED the
statement;
state the manner in which the DOCUMENT was
communicated to EMPLOYEES;
state the manner, if any, in which EMPLOYEES
acknowledged receipt of the DOCUMENT or knowledge
of its contents, or both;
state, if you contend that the EMPLOYEE failed to use
any available internal complaint procedures, all facts
that support that contention; and
state the nature of the complaint;
state the name and ADDRESS of each PERSON to
whom the complaint was made;
state the name, ADDRESS, telephone number, and job
title of each PERSON who investigated the complaint;
DISC-002
204.6 Were there any communications between the
EMPLOYEE (or the EMPLOYEE’S HEALTH CARE
PROVIDER) and the EMPLOYER about any possible
accommodation of EMPLOYEE? If so, for each
communication:
(b)
(d)
(a)
(c)
(b)
(d)
(e)
(f)
(a)
(c)
204.7 What did the EMPLOYER consider doing to
accommodate the EMPLOYEE? For each accommodation
considered:
205.1 Do you contend that the EMPLOYER took any
ADVERSE EMPLOYMENT ACTION against you in
violation of public policy? If so:
(b)
(a)
206.1 Did the EMPLOYER'S agents or employees
PUBLISH any of the allegedly defamatory statements
identified in the PLEADINGS? If so, for each statement:
(b)
(a)
(c)
(d)
(e)
206.2 State the name and ADDRESS of each agent or
employee of the EMPLOYER who responded to any
inquiries regarding the EMPLOYEE after the EMPLOYEE’S
TERMINATION .
206.3 State the name and ADDRESS of the recipient and
the substance of each post-TERMINATION statement
PUBLISHED about EMPLOYEE by any agent or employee
of EMPLOYER.
207.1 Were there any internal written policies or regulations
of the EMPLOYER that apply to the making of a complaint
of the type that is the subject matter of this lawsuit? If so:
(b)
(d)
(e)
(a)
(c)
207.2 Did the EMPLOYEE complain to the EMPLOYER
about any of the unlawful conduct alleged in the
PLEADINGS? If so, for each complaint:
(b)
(d)
(e)
(a)
(c)
state the name, ADDRESS, telephone number, and
job title of each PERSON who was interviewed or who
provided an oral or written statement as part of the
investigation.
209.0 Other Employment Claims by Employee or Against
Employer
state whether the EMPLOYEE who made the
complaint was made aware of the actions taken by the
EMPLOYER in response to the complaint, and, if so,
state how and when;
208.0 Governmental Complaints
state whether the action has been resolved or is
pending.
state the date on which it was filed;
state the name and ADDRESS of the agency with
which it was filed;
state whether the action has been resolved or is
pending.
210.0 Loss of Income—Interrogatories to Employee
state whether any findings or conclusions regarding
the complaint or charge have been made, and, if so,
the date and description of the agency’s findings or
conclusions.
state the name, ADDRESS, telephone number, and
job title of each PERSON who participated in making
decisions about how to conduct the investigation; and
DISC-002 [Rev. January 1, 2009]
FORM INTERROGATORIES–EMPLOYMENT LAW
Page 6 of 8
state the name, ADDRESS, telephone number, and
job title of each PERSON who was interviewed or who
provided an oral or written statement as part of the
investigation of the complaint;
state the nature and date of any action taken in
response to the complaint;
identify all DOCUMENTS relating to the complaint, the
investigation, and any action taken in response to the
complaint; and
state the name, ADDRESS, and telephone number of
each PERSON who has knowledge of the
EMPLOYEE’S complaint or the EMPLOYER'S
response to the complaint.
state the number assigned to the claim, complaint, or
charge by the agency;
state the nature of each claim, complaint, or charge
made;
state the date on which the EMPLOYER was notified
of the claim, complaint, or charge;
state the name, ADDRESS, and telephone number of
all PERSONS within the governmental agency with
whom the EMPLOYER has had any contact or
communication regarding the claim, complaint, or
charge;
state whether a right to sue notice was issued and, if
so, when; and
state the nature and date of any investigation done or
any other action taken by the EMPLOYER in response
to the claim, complaint, or charge:
state the name, ADDRESS, telephone number, and
job title of each person who investigated the claim,
complaint, or charge;
state the name, ADDRESS, and telephone number of
any attorney representing the EMPLOYER; and
state the court, names of the parties, and case number
of the civil action;
state the name, ADDRESS, and telephone number of
each employee who filed the action;
state the name, ADDRESS, and telephone number of
any attorney representing the EMPLOYEE; and
state the court, names of the parties, and case number
of the civil action;
state the name, ADDRESS, and telephone number of
each employer against whom the action was filed;
DISC-002
(i)
(f)
(j)
(h)
(g)
208.1 Did the EMPLOYEE file a claim, complaint, or charge
with any governmental agency that involved any of the
material allegations made in the PLEADINGS? If so, for
each claim, complaint, or charge:
208.2 Did the EMPLOYER respond to any claim,
complaint, or charge identified in Interrogatory 208.1? If so,
for each claim, complaint, or charge:
(b)
(d)
(e)
(a)
(c)
(f)
(h)
(g)
(b)
(a)
(c)
210.4 Have you attempted to minimize the amount of your
lost income? If so, describe how; if not, explain why not.
209.1 Except for this action, in the past 10 years has the
EMPLOYEE filed a civil action against any employer
regarding the EMPLOYEE’S employment? If so, for each
civil action:
(d)
(b)
(d)
(a)
(c)
209.2 Except for this action, in the past 10 years has any
employee filed a civil action against the EMPLOYER
regarding his or her employment? If so, for each civil action:
(b)
(d)
(a)
(c)
210.1 Do you attribute any loss of income, benefits, or
earning capacity to any ADVERSE EMPLOYMENT
ACTION? (If your answer is “no,” do not answer
Interrogatories 210.2 through 210.6.)
210.2 State the total amount of income, benefits, or earning
capacity you have lost to date and how the amount was
calculated.
210.3 Will you lose income, benefits, or earning capacity in
the future as a result of any ADVERSE EMPLOYMENT
ACTION? If so, state the total amount of income, benefits,
or earning capacity you expect to lose, and how the amount
was calculated.
212.0 Physical, Mental, or Emotional Injuries—
Interrogatories to Employee
state when the new employment commenced;
state the hourly rate or monthly salary for the new
employment; and
state the benefits available from the new employment.
211.0 Loss of Income—Interrogatories to Employer
[See instruction 2(d).]
a description of the injury;
whether the complaint is subsiding, remaining the
same, or becoming worse; and
the name, ADDRESS, and telephone number;
describe what more EMPLOYEE should have done;
state the names, ADDRESSES, and telephone
numbers of all PERSONS who have knowledge of the
facts that support your contention; and
the name of the medication;
the date prescribed or furnished;
the dates you began and stopped taking it; and
state the amount of claimed lost income that you
dispute;
identify all DOCUMENTS that support your contention
and state the name, ADDRESS, and telephone
number of the PERSON who has each DOCUMENT.
the date;
the cost; and
DISC-002 [Rev. January 1, 2009]
FORM INTERROGATORIES–EMPLOYMENT LAW
Page 7 of 8
identify all DOCUMENTS that support your contention
and state the name, ADDRESS, and telephone
number of the PERSON who has each DOCUMENT.
state all facts upon which you base your contention;
state the names, ADDRESSES, and telephone
numbers of all PERSONS who have knowledge of the
facts; and
the nature;
the name, ADDRESS, and telephone number of
each HEALTH CARE PROVIDER .
the cost to date.
the name, ADDRESS and telephone number of the
PERSON who prescribed or furnished it;
the charges to date.
the dates you received consultation, examination, or
treatment; and
the type of consultation, examination, or
treatment provided;
the frequency and duration.
DISC-002
210.6 Have you obtained other employment since any
ADVERSE EMPLOYMENT ACTION? If so, for each new
employment:
210.5 Have you purchased any benefits to replace any
benefits to which you would have been entitled if the
ADVERSE EMPLOYMENT ACTION had not occurred? If
so, state the cost for each benefit purchased.
(b)
(a)
(c)
211.1 Identify each type of BENEFIT to which the
EMPLOYEE would have been entitled, from the date of the
ADVERSE EMPLOYMENT ACTION to the present, if the
ADVERSE EMPLOYMENT ACTION had not happened and
the EMPLOYEE had remained in the same job position. For
each type of benefit, state the amount the EMPLOYER
would have paid to provide the benefit for the EMPLOYEE
during this time period and the value of the BENEFIT to the
EMPLOYEE.
211.2 Do you contend that the EMPLOYEE has not made
reasonable efforts to minimize the amount of the
EMPLOYEE’S lost income? If so:
211.3 Do you contend that any of the lost income claimed
by the EMPLOYEE, as disclosed in discovery thus far in this
case, is unreasonable or was not caused by the ADVERSE
EMPLOYMENT ACTION? If so:
(b)
(a)
(c)
(b)
(d)
(a)
(c)
212.1 Do you attribute any physical, mental, or emotional
injuries to the ADVERSE EMPLOYMENT ACTION? (If your
answer is “no,” do not answer Interrogatories 212.2 through
212.7.)
212.2 Identify each physical, mental, or emotional injury that
you attribute to the ADVERSE EMPLOYMENT ACTION
and the area of your body affected.
212.3 Do you still have any complaints of physical, mental,
or emotional injuries that you attribute to the ADVERSE
EMPLOYMENT ACTION? If so, for each complaint state:
(b)
(a)
(c)
212.4 Did you receive any consultation or examination
(except from expert witnesses covered by Code of Civil
Procedure section 2034) or treatment from a HEALTH
CARE PROVIDER for any injury you attribute to the
ADVERSE EMPLOYMENT ACTION? If so, for each
HEALTH CARE PROVIDER state:
(b)
(d)
(a)
(c)
212.5 Have you taken any medication, prescribed or not, as
a result of injuries that you attribute to the ADVERSE
EMPLOYMENT ACTION? If so, for each medication state:
(b)
(d)
(e)
(a)
(c)
212.6 Are there any other medical services not previously
listed in response to interrogatory 212.4 (for example,
ambulance, nursing, prosthetics) that you received for
injuries attributed to the ADVERSE EMPLOYMENT
ACTION? If so, for each service state:
(b)
(d)
(a)
(c)
215.0 Investigation
the date of the interview; and
the nature, duration, and estimated cost of the
treatment.
the name, ADDRESS, and telephone number of the
PERSON who conducted the interview.
213.0 Other Damages—Interrogatories to Employee
the nature;
the date it occurred;
the amount; and
the name, ADDRESS, and telephone number of each
PERSON who has knowledge of the nature or amount
of the damage.
the name, ADDRESS, and telephone number of the
individual who obtained the statement;
216.0 Denials and Special or Affirmative Defenses
214.0 Insurance
identify all DOCUMENTS and all other tangible things,
that support your denial or special or affirmative
defense, and state the name, ADDRESS, and
telephone number of the PERSON who has each
DOCUMENT .
the kind of coverage;
the name, ADDRESS, and telephone number of each
named insured;
the policy number;
217.0 Response to Request for Admissions
state the number of the request;
the name, ADDRESS, and telephone number of the
custodian of the policy.
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.
Page 8 of 8
DISC-002 [Rev. January 1, 2009]
FORM INTERROGATORIES–EMPLOYMENT LAW
the name and ADDRESS of each HEALTH CARE
PROVIDER;
the complaints for which the treatment was advised;
and
the name and ADDRESS of the insurance company;
the limits of coverage for each type of coverage
contained in the policy;
whether any reservation of rights or controversy or
coverage dispute exists between you and the
insurance company; and
state the names, ADDRESSES, and telephone
numbers of all PERSONS who have knowledge of
those facts; and
state all facts upon which you base your response;
state the names, ADDRESSES, and telephone
numbers of all PERSONS who have knowledge of
those facts; and
state all facts upon which you base the denial or special
or affirmative defense;
the name, ADDRESS, and telephone number of each
PERSON who has the original statement or a copy.
the date the statement was obtained; and
the name, ADDRESS, and telephone number of the
individual from whom the statement was obtained;
the name, ADDRESS, and telephone number of the
individual interviewed;
DISC-002
212.7 Has any HEALTH CARE PROVIDER advised that
you may require future or additional treatment for any
injuries that you attribute to the ADVERSE EMPLOYMENT
ACTION? If so, for each injury state:
(b)
(a)
(c)
213.1 Are there any other damages that you attribute to the
ADVERSE EMPLOYMENT ACTION? If so, for each item of
damage state:
(b)
(d)
(a)
(c)
213.2 Do any DOCUMENTS support the existence or
amount of any item of damages claimed in Interrogatory
213.1? If so, identify the DOCUMENTS and state the name,
ADDRESS, and telephone number of the PERSON who has
each DOCUMENT .
214.1 At the time of the ADVERSE EMPLOYMENT
ACTION, was there in effect any policy of insurance
through which you were or might be insured in any manner
for the damages, claims, or actions that have arisen out of
the ADVERSE EMPLOYMENT ACTION? If so, for each
policy state:
214.2 Are you self-insured under any statute for the
damages, claims, or actions that have arisen out of the
ADVERSE EMPLOYMENT ACTION? If so, specify the
statute.
(b)
(d)
(e)
(a)
(c)
(f)
(g)
215.1 Have YOU OR ANYONE ACTING ON YOUR
BEHALF interviewed any individual concerning the
ADVERSE EMPLOYMENT ACTION? If so, for each
individual state:
215.2 Have YOU OR ANYONE ACTING ON YOUR
BEHALF obtained a written or recorded statement from any
individual concerning the ADVERSE EMPLOYMENT
ACTION? If so, for each statement state:
(b)
(a)
(c)
(b)
(d)
(a)
(c)
216.1 Identify each denial of a material allegation and each
special or affirmative defense in your PLEADINGS and for
each:
(b)
(a)
(c)
217.1 Is your response to each request for admission
served with these interrogatories an unqualified admission?
If not, for each response that is not an unqualified
admission:
(b)
(d)
(a)
(c)
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FORM INTERROGATORIESEMPLOYMENT LAW: DISC-002 (California)

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Completed 6 March 2021

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