13.2 Has a written report been prepared on the
surveillance? If so, for each written report state:
(a) the title;
(b) the date;
12.4 Do YOU OR ANYONE ACTING ON YOUR BEHALF
know of any photographs, films, or videotapes depicting any
place, object, or individual concerning the INCIDENT or
plaintiff's injuries? If so, state:
(a) the number of photographs or feet of film or videotape;
(b) the places, objects, or persons photographed, filmed, or
videotaped;
(d) the name, ADDRESS, and telephone number of each
PERSON who has the original or a copy.
(c) the date the photographs, films, or videotapes were
taken;
14.0 Statutory or Regulatory Violations
(d) the name, ADDRESS, and telephone number of the
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 the name, ADDRESS, and telephone number of
each PERSON and the statute, ordinance, or regulation that
was violated.
(e) the name, ADDRESS, and telephone number of each
PERSON who has the original or a copy of the
photographs, films, or videotapes.
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 Civil Procedure sections 2034.210–
2034.310) concerning the INCIDENT? If so, for each item
state:
14.2 Was any PERSON cited or charged with a violation of
any statute, 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
(c) the name, ADDRESS, and telephone number of each
PERSON who has it.
citation or charge and, if so, the plea entered; and
(d) the name and ADDRESS of the court or administrative
agency, names of the parties, and case number.
12.6 Was a report made by any PERSON concerning the
INCIDENT? If so, state:
15.0 Denials and Special or Affirmative Defenses
(a) the name, title, identification number, and employer of
the PERSON who made the report;
15.1 Identify each denial of a material allegation and each
(b) the date and type of report made;
special or affirmative defense in your pleadings and for
each:
(c) the name, ADDRESS, and telephone number of the
PERSON for whom the report was made; and
(a) state all facts upon which you base the denial or special
(d) the name, ADDRESS, and telephone number of each
PERSON who has the original or a copy of the report.
or affirmative defense;
(b) state the names, ADDRESSES, and telephone numbers
of all PERSONS who have knowledge of those facts;
and
(c) identify all DOCUMENTS and other tangible things that
12.7 Have YOU OR ANYONE ACTING ON YOUR
BEHALF inspected the scene of the INCIDENT? If so, for
each inspection state:
support your denial or special or affirmative defense, and
state the name, ADDRESS, and telephone number of
the PERSON who has each DOCUMENT.
(a) the name, ADDRESS, and telephone number of the
individual making the inspection (except for expert
witnesses covered by Code of Civil Procedure
sections 2034.210–2034.310); and
16.0 Defendant’s Contentions—Personal Injury
(b) the date of the inspection.
13.0 Investigation—Surveillance
(a) state the name, ADDRESS, and telephone number of
the PERSON;
13.1 Have YOU OR ANYONE ACTING ON YOUR BEHALF
conducted surveillance of any individual involved in the
INCIDENT or any party to this action? If so, for each sur-
veillance state:
(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; and
(a) the name, ADDRESS, and telephone number of the
individual or party;
(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.
(b) the time, date, and place of the surveillance;
(c) the name, ADDRESS, and telephone number of the
individual who conducted the surveillance; and
(d) the name, ADDRESS, and telephone number of each
PERSON who has the original or a copy of any
surveillance photograph, film, or videotape.
(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.
DISC-001 [Rev. January 1, 2008]
Page 6 of 8
FORM INTERROGATORIES—GENERAL
individual taking the photographs, films, or videotapes;
and
(a) the type (i.e., diagram, reproduction, or model);
(b) the subject matter; and
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; and
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:
(c) the name, ADDRESS, and telephone number of the
individual who prepared the report; and
DISC-001