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JOSHUA S. FALAKASSA (SBN: 295045) FlLEO/EiOOl
FALAKASSA LAW, P C.
2 1901 Avenue ofthe Stars Suite # 450
Los Angeles, Califomiia 90067 JUN 2 9 2022
3
Tel.: (818) 456-6168; Fax: (888) 505-0868 By: E. Macdonald
4 Email: josh@falakassalaw.com Deputy Clerk
5 ARASH S. KHOSROWSHAHI (SBN: 293246)
LIBERTY MAN LAW, P.C.
6 1010 F Street, Ste, 300
Sacramento, Califomia 95814
7 Tel.: (916) 573-0469; Fax: (866) 700-0787
Email: ash@libertymanlaw.com
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Attomeys for Plaintiff,
9 SAJIDA ZAMAN
10 SUPERIOR COURT OF CALIFORNIA
11 COUNTY OF SACRAMENTO
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13 SAJIDA ZAMAN, CASE NO.: 34-2019-00252121
RESERVATION ID: 2656706
14 Plaintiff, DECLARATION OF ARASH S.
15 vs. KHOSROWSHAHI IN SUPPORT OF
MOTION TO COMPEL DISCOVERY
16 LIQUI-BOX CORPORATION, and DOES RESPONSES AS TO FORM
through 20, inclusive. INTERROGATORIES-GENERAL, SET
17 TWO (2), AND MONETARY
Defendants. SANCTIONS
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Concurrently filed with Plaintiff's Motion to
19 Deem Requests for Admissions Admitted and
Monetary Sanctions
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Date: September 1, 2022'ry ^
21 Time: 1:30pm li % i^'AA
22 Dept.: 53
Trial Date: September 12, 2022
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1, ARASH KHOSROWSHAHI, declare as follows:
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1. I am an attomey licensed to practice law in the State of Califomia. My State Bar Numbei
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is 293246.
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2. I represent Plaintiff Sajida Zaman ("Plaintiff) in the above-entitled action. I have
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knowledge of the facts stated herein and can testify competently thereto.
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DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT
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1 3. On May 27, 2022 I on behalf of Plaintiff served her second set of Form Interrogatories-
2 General propounded against Defendant via email. (Attached as Exhibit A is a tme and
3 correct copy of Plaintiff Sajida Zaman's Form Interrogatories—General, Set Two to
4 Defendant [hereinafter "FROGs"]; attached as Exhibit B is a tme and correct copy of
5 Plaintiffs Proof of Service, showing a service date of May 27, 2022 arid executed May 31,
6 2022.) The FROGs were concurrently served with Plaintiffs Requests for Admissions to
7 Defendant Liqui-Box Corporation (Set One) ("RFAs") (See Exhibit B), and contained a
8 single interrogatory. No. 17.1, which required the Defendant to provide all facts, witnesses,
9 and documents in support of any denial or qualified admission to the RFAs. (See Exhibit
10 A),
11 4. As of this writing Defendant did not serve any objections or responses to the FROGs. This
12 was despite the fact that Defendant did serve objections on concurrently-served discovery
13 requests from the same email the FROGs and RFAs were served in. (See Exhibit B.)
14 5. I am a graduate of the University of Califomia, Berkeley School of Law ("Boalt Hall"), a
15 Top 14 law school. I further graduated with a Bachelor of Science in Mathematics (Honors)
16 and a Bachelor of Arts in Philosophy (Highest Honors) from the University of Califomia,
17 Davis in 2009. I mn a solo practice in Sacramento, Califomia, and have been practicing
18 law since December 2013.1 primarily handle unlimited civil litigation cases in employment
19 law, which include class-action wage-and-hour cases as well as wrongful termination
20 cases. I practice throughout the State of Califomia, having litigated cases successfiilly in
21 the greater Sacramento Area, the Bay Area, and the greater Los Angeles area. I have also
22 negotiated six-figure/seven-figure settlements for class-action wage-and-hour matters as
23 well as six-figure settlements for wrongful termination matters. I was selected as a Super
24 Lawyer Rising Star in Northem Califomia in 2020 and 2021, a distinction that is reserved
25 for the top 2.5% of lawyers practicing less than 10 years. For these reasons, I believe an
26 hourly rate of $500 is a reasonable hourly rate.
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DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT
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6. I spent 1.5 hours researching and drafting this instant Motion and related documents herein,
2 resulting in $750.00 in reasonable attomey's fees. Further, Plaintiff incurs a $60 motion
3 filing fee. I therefore respectfully request sanctions in the amount of $810.00 for reasonable
4 costs and attomey's fees.
5 I declare under penalty of perjury under the laws of the State of Califomia that the
6 foregoing is tme and correct.
7 Dated: June 29, 2022
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Arash S. Khosrowshahi
10 Attomey for Plaintiff Sajida Zaman
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DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT
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EXHIBIT A
DISC-001
ATTORNEY OR PARTY WITHOUT ATTORNEY (Nama, State Bar number, and address):
ARASH S. KHOSROWSHAHI (SBN: 293246)
LIBERTY MAN LAW, P.C, 1010 F Street, Ste. 300, Sacramento, CA 95814
TELEPHONENO.: 916.573.0469
FAX NO. IOptional): 866.700.0787
E-MAILADDRESS IOptional): ash(ajlibertvmanlaw.com
ATTORNEY FOR (Name): SAJ1 DA ZAMAN
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SACRAMENTO
SHORT TITLE OF CASE:
ZAMAN V. LIQUI-BOX CORPORATION, et al.
FORM INTERROGATORIES—GENERAL CASE NUMBER:
34-2019-00252121
A s k i n g Party: LIQUI-BOX CORPORATION
A n s w e r i n g Party: SAJIDA ZAMAN
Set No.: 2
Sec. 1. Instructions to All Parties (c) Each answer must.be as complete and straightforward as
(a) Interrogatories are written questions prepared by a party to an the infonmation reasonably available to you, including the
action that are sent to any other party in the action to be infonmation possessed by your attomeys or agents, permits.
answered under oath. The interrogatories below are form If an Interrogatory cannot be answered completely, answer it
interrogatories approved for use in civil cases. to the extent possible.
(b) For time limitations, requirements for service on other parties, (d) If you do not have enough personal knowledge to fully
and other details, see Code of Civil Procedure sections answer an Interrogatory, say so, but make a reasonable and
2030.010-2030.410 and the cases construing those sections. good faith effort to get the information by asking other
(c) These form interrogatories do not change existing law persons or organizations, unless the information is equally
relating to interrogatories nor do they affect an answering available to the asking party.
party's right to assert any privilege or make any objection. (e) Whenever an interrogatory may be answered by referring to
Sec. 2. Instructions to the Asking Party a document, the document may be attached as an exhibit to
(a) These Interrogatories are designed for optional use by parties the response and referred to in the response. If the
In unlimited civil cases where the amount demanded exceeds document has more than one page, refer to the page and
$25,000. Separate interrogatories, Fonm Interrogatories— section where the answer to the inten-ogatory can be found.
Limited Civil Cases (Economic Litigation) (fomi DISC-004),
which have no subparts, are designed for use in limited civil (0 Whenever an address and telephone number for the same
person are requested in more than one Interrogatory, you
cases where the amount demanded is $25,000 or less;
are required to fumish them in answering only the first
however, those interrogatories may also be used in unlimited
Interrogatory asking for that information.
civil cases.
(b) Check the box next to each intenrogatory that you want the (g) If you are asserting a privilege or making an objection to an
answering party to answer. Use care In choosing those interrogatory, you must specifically assert the privilege or
Interrogatories that are applicable to the case. state the objection in your written response.
(c) You may insert your own definition of INCIDENT in Section 4, (h) Your answers to these interrogatories must be verified,
but only where the action arises from a course of conduct or a dated, and signed. You may wish to use the following form
series of events occun-ing over a period of time. at the end of your answers:
(d) The interrogatories in section 16.0, Defendant's Contentions-
/ declare underpenalty ofperjury under the laws ofthe State of
Personal Injury, should not be used until the defendant has
Califomia that the foregoing answers are true and correct.
had a reasonable opportunity to conduct an investigation or
discovery of plaintiffs injuries and damages.
(e) Additional interrogatories may be attached. (Date) ISIGNATURE)
Sec. 3. Instructions to the Answering Party Sec. 4. Definitions
(a) An answer or other appropriate response must be given to Words in BOLDFACE CAPITALS in these inten-ogatories are
each inten-ogatory checked by the asking party. defined as follows:
(b) As a general rule, within 30 days after you are served with (a) (Check one of the following):
these inten-ogatories, you must serve your responses on the
I I (1) INCIDENT Includes the circumstances and
asking party and serve copies of your responses on all other
events surrounding the alleged accident, injury,
parties to the action who have appeared. See Code of Civil
or other occun-ence or breach of contract giving
Procedure sections 2030.260-2030.270 for details.
rise to this action or proceeding.
Page < ot t
form Approved for Optional Use Code of Civil Procedure, §§
Judicial Council of California FORM INTERROGATORIES—GENERAL 2030.010-2030.410,2033.710
DISC-001 [Rev. January 1, 2008] Mww.courrs.CQ.90v
DISC-001
] (2) INCIDENT means (insert your definition here or on a 1.0 Identity of Persons Answering These interrogatories
separate, attached sheet labeled "Sec. 4(a)(2)"): I 1 1.1 State the name, ADDRESS, telephone number, and
relationship to you of each PERSON who prepared or
assisted in the preparation of the responses to these
interrogatories. (Do not Identify anyone who simply typed
or reproduced the responses)
2.0 General Background Information individual—
(b) YOU OR ANYONE ACTING ON YOUR BEHALF includes I I 2.1 State:
you, your agents, your employees, your insurance (a) your name;
companies, their agents, their employees, your attomeys, (b) every name you have used in the past; and
your accountants, your investigators, and anyone else acting
(c) the dates you used each name.
on your behalf.
I I 2.2 State the date and place of your birth.
(c) PERSON includes a natural person, firm, association,
organization, partnership, business, trust, limited liability I I 2.3 At the time of the INCIDENT, did you have a driver's
company, corporation, or public entity. license? If so state:
(d) DOCUMENT means a writing, as defined in Evidence Code (a) the state or other issuing entity;
, section 250, and includes the original or a copy of (b) the license number and type;
handwriting, typewriting, printing, photostats, photographs, (c) the date of issuance; and
electronically stored information, and every other means of (d) all restrictions.
recording upon any tangible thing and form of communicating
I I 2.4 At the time of the INCIDENT, did you have any other
or representation, induding letters, words, pictures, sounds,
or symbols, or combinations of them. permit or license for the operation of a motor vehicle? If so,
state:
(e) HEALTH CARE PROVIDER includes any PERSON refen-ed
to in Code of Civil Procedure section 667.7(e)(3). (a) the state or other issuing entity;
(f) ADDRESS means the street address, including the city, (b) the license number and type;
state, and zip code. (c) the date of issuance; and
(d) all restrictions.
Sec. 5. Interrogatories
I ~i 2.5 State:
The following interrogatories have been approved by the Judicial (a) your present residence ADDRESS;
Council under Code of Civil Procedure section 2033.710:
(b) your residence ADDRESSES for the past five years;
CONTENTS and
1.0 Identity of Persons Answering These Inten'ogatories (c) the dates you lived at each ADDRESS.
2.0General Background Information—Individual 2.6 State:
3.0General Background Information—Business Entity (a) the name, ADDRESS, and telephone number of your
4.0 Insurance present employer or place of self-employment; and
5.0//?esen/ed7
e.OPhysical, Mental, or Emotional Injuries (b) the name, ADDRESS, dates of employment, job title,
7.0 Property Damage and nature of work for each employer or self-
8.0Loss of Income or Earning Capacity employment you have had from five years before the
9.0Other Damages INCIDENT until today.
10.0 Medical History 1 I 2.7 State:
ll.OOther Claims and Previous Claims (a) the name and ADDRESS of each school or other
12.0lnvestigation—General academic or vocational institution you have attended,
13.0lnvestigation—Surveillance
beginning with high school;
14.0Statutory or Regulatory Violations
15.0Denials and Special or Affirmative Defenses (b) the dates you attended;
16.0 Defendant's Contentions Personal Injury (c) the highest grade level you have completed; and
17.0Responses to Request for Admissions (d) the degrees received.
18.0/Reserved7
I I 2.8 Have you ever been convicted of a felony? If so, for
19.0//?esen/ec(/
2O.OH0W the Incident Occurred—Motor Vehicle each conviction state:
25.0/Reserved7 (a) the city and state where you were convicted;
30.0/F?ese/veai/ (b) the date of conviction;
40.0/^Resen/ecii/ (c) the offense; and
50.0Contract
eO.O/Reserved/ (d) the court and case number.
70.0Unlawful Detainer [See separate form DISC-003] I I 2.9 Can you speak English with ease? If not, what
lOI.OEconomic Litigation [See separate form DISC-004] language and dialect do you normally use?
200.0Employment Law [See separate fonn DISC-002] Family I I 2.10 Can you read and write English with ease? If not,
Law [See separate form FL-745/ what language and dialect do you normally use?
•ISC-001 [Rev. January 1, 2008] Page 2 of 8
FORM INTERROGATORIES—GENERAL
DISC-001
] 2.11 At the time of the INCIDENT were you acting as an 3.4 Are you a joint venture? If so, state:
agent or employee for any PERSON? If so, state: (a) the current joint venture name;
(a) the name, ADDRESS, and telephone number of that (b) all other names used by the joint venture during the
PERSON: and past 10 years and the dates each was used;
(b) a description of your duties. (c) the name and ADDRESS of each joint venturer; and
] 2.12 At the time of the INCIDENT did you or any other
(d) the ADDRESS of the principal place of business.
person have any physical, emotional, or mental disability or
condition that may have contributed to the occurrence of the I I 3.5 Are you an unincorporated association? If so, state:
INCIDENT? If so, for each person state: (a) the current unincorporated association name;
(a) the name, ADDRESS, and telephone number; (b) all other names used by the unincorporated
(b) the nature of the disability or condition; and association during the past 10 years and the dates
(c) the manner in which the disability or condition each was used; and
contributed to the occurrence of the INCIDENT. (c) the ADDRESS of the principal place of business.
] 2.13 Within 24 hours before the INCIDENT did you or any I I 3.6 Have you done business under a fictitious name during
person involved in the INCIDENT use or take any of the the past 10 years? If so, for each fictitious name state;
following substances: alcoholic beverage,.marijuana, or
other drug or medication of any kind (prescription or not)? If (a) the name;
so, for each person state: (b) the dates each was used;
(a) the name, ADDRESS, and telephone number; (c) the state and county of each fictitious name filing; and
(b) the nature or description of each substance; (d) the ADDRESS of the principal place of business.
(c) the quantity of each substance used or taken; I I 3.7 Within the past five years has any public entity
(d) the date and time of day when each substance was registered or licensed your business? If so, for each license
used or taken; or registration:
(e) the ADDRESS where each substance was used or (a) identify the license or registration;
taken;
(b) state the name of the public entity; and
(f) the name, ADDRESS, and telephone number of each
person who was present when each substance was (c) state the dates of issuance and expiration.
used or taken; and 4.0 Insurance
(g) the name, ADDRESS, and telephone number of any I I 4.1 At the time of the INCIDENT, was there in effect any
HEALTH CARE PROVIDER who prescribed or policy of insurance through which you were or might be
fumished the substance and the condition for which it insured in any manner (for example, primary, pro-rata, or
was prescribed or furnished. excess liability coverage or medical expense coverage) for
3.0 General Background Information—Business Entity the damages, claims, or actions that have arisen out of the
INCIDENT? If so, for each policy state:
] 3.1 Are you a corporation? If so, state:
(a) the name stated in the current articles of Incorporation; (a) the kind of coverage;
(b) all other names used by the corporation during the past (b) the name and ADDRESS of the insurance company;
10 years and the dates each was used; (c) the name, ADDRESS, and telephone number of each
(c) the date and place of Incorporation; named insured;
(d) the ADDRESS of the principal place of business; and (d) the policy number;
(e) whether you are qualified to do business In California.
(e) the limits of coverage for each type of coverage
] 3.2 Are you a partnership? If so, state:
contained in the policy;
(a) the current partnership name;
(f) whether any reservation of rights or controversy or
(b) all other names used by the partnership during the past
coverage dispute exists between you and the
10 years and the dates each was used; insurance company; and
(c) whether you are a limited partnership and, if so, under
(g) the name, ADDRESS, and telephone number of the
the laws of what jurisdiction;
custodian of the policy.
(d) the name and ADDRESS of each general partner; and
I i 4.2 Are you self-insured under any statute for the
(e) the ADDRESS of the principal place of business. damages, claims, or actions that have arisen out of the
3.3 Are you a limited liability company? If so, state: INCIDENT? If so, specify the statute.
(a) the name stated in the current articles of organization; 5.0 [Resen/edj
(b) all other names used by the company during the past 6.0 Physical, Mental, or Emotional Injuries
10 years and the date each was used;
I I 6.1 Do you attribute any physical, mental, or emotional
(c) the date and place of filing of the articles of injuries to the INCIDENT? (If your answer is "no," do not
organization; answer interrogatories 6.2 through 6.7).
(d) the ADDRESS of the principal place of business; and I I 6.2 Identify each injury you attribute to the INCIDENT and
(e) whether you are qualified to do business in Califomia. the area of your body affected.
OISC.001 (Rev. January 1. 2008) FORM INTERROGATORIES—GENERAL Page 3 of S
DISC-001
I 6.3 Do you still have any complaints that you attribute to the (c) state the amount of damage you are claiming for
INCIDENT? If so, for each complaint state: each item of property and how the amount was
(a) a description; calculated; and
(b) whether the complaint is subsiding, remaining the (d) if the property was sold, state the name, ADDRESS,
same, or becoming worse; and and telephone number of the seller, the date of sale,
and the sale price.
(c) the frequency arid duration.
I 6.4 Did you receive any consultation or examination (except I I 7.2 Has a written estimate or evaluation been made for any
from expert witnesses covered by Code of Civil Procedure item of property referred to In your answer to the preceding
sections 2034.210-2034.310) or treatment from a HEALTH inten-ogatory? If so, for each estimate or evaluation state:
CARE PROVIDER for any Injury you attribute to the (a) the name, ADDRESS, and telephone number of the
INCIDENT? If so, for each HEALTH CARE PROVIDER PERSON who prepared it and the date prepared;
state:
(b) the name, ADDRESS, and telephone number of each
(a) the name, ADDRESS, and telephone number;
PERSON who has a copy of it; and
(b) the type of consultation, examination, or treatment
(c) the amount of damage stated.
provided;
(c) the dates you received consultation, examination, or I I 7.3 Has any item of property referred to in your answer to
treatment; and interrogatory 7.1 been repaired? If so, for each item state:
(d) the charges to date. (a) the date repaired;
I 6.5 Have you taken any medication, prescribed or hot, as a (b) a description of the repair;
result of injuries that you attribute to the INCIDENT? If so,
(c) the repair cost;
for each medication state:
(d) the name, ADDRESS, and telephone number of the
(a) the name;
PERSON who repaired it;
(b) the PERSON who prescribed or furnished il;
(e) the name, ADDRESS, and telephone number of the
(c) the date it was prescribed or furnished; PERSON who paid for the repair.
(d) the dates you began and stopped taking it; and
8.0 Loss of Income or Earning Capacity
(e) the cost to date.
I 6.6 Are there any other medical services necessitated I I 8.1 Do you attribute any loss of Income or earning capacity
by the injuries that you attribute to the INCIDENT that to the INCIDENT? (If your answer is "no." do not answer
were not previously listed (for example, ambulance, nursing, interrogatories 8.2 through 8.8).
prosthetics)? If so, for each service state: I I 8.2 State:
(a) the nature; (a) the nature of your work;
(b) the date; (b) your job title at the time of the INCIDENT; and
(c) the cost; and (c) the date your employment began.
(d) the name, ADDRESS, and telephone number 8.3 State the last date before the INCIDENT that you
of each provider. worked for compensation.
I 6.7 Has any HEALTH CARE PROVIDER advised that you
may require future or additional treatment for any injuries 8.4 State your monthly Income at the time of the INCIDENT
that you attribute to the INCIDENT? If so, for each injury and how the amount was calculated.
state: 8.5 State the date you retumed to work at each place of
(a) the name and ADDRESS of each HEALTH CARE employment following the INCIDENT.
PROVIDER; 8.6 State the dates you did not work and for which you lost
(b) the complaints for which the treatment was income as a result of the INCIDENT.
advised; and
I I 8.7 State the total income you have lost to date as a result
(c) the nature, duration, and estimated cost of
of the INCIDENT and how the amount was calculated.
the treatment.
.0 Property Damage 8.8 Will you lose income in the future as a result of the
INCIDENT? If so. state:
I 7.1 Do you attribute any loss of or damage to a vehicle or
other property to the INCIDENT? If so, for each item of (a) the facts upon which you base this contention;
property: (b) an estimate of the amount;
(a) describe the property; (c) an estimate of how long you will be unable to work;
(b) describe the nature and location of the damage to the and
property; (d) how the claim for future income is calculated.
DISC-001 [Rev. January 1, 200BJ Page 4 of 8
FORM INTERROGATORIES—GENERAL
DISC-001
9.0 Other Damages (c) the court, names of the parties, and case number of
any action filed;
I I 9.1 Are there any other damages that you attribute to the
(d) the name, ADDRESS, and telephone number of any
INCIDENT? If so, for each item of damage state:
attorney representing you;
(a) the nature; (e) whether the claim or action has been resolved or is
pending; and
(b) the date it occun-ed;
(f) a description of the Injury.
(c) the amount; and 11.2 In the past 10 years have you made a written claim or
(d) the name, ADDRESS, and telephone number of each demand for workers' compensation benefits? If so, for each
PERSON to whom an obligation was Incuri-ed. claim or demand state:
(a) the date, time, and place of the INCIDENT giving rise
9.2 Do any DOCUMENTS support the existence or amount to the claim;
of any Item of damages claimed in interrogatory 9.1? If so,
(b) the name, ADDRESS, and telephone number of your
describe each document and state the name, ADDRESS,
employer at the time of the injury;
and telephone number of the PERSON who has each
DOCUMENT. (c) the name, ADDRESS, and telephone number ofthe
workers' compensation insurer and the claim nurnber;
10.0 Medical History (d) the period of time during which you received workers'
I I 10.1 At any time before the INCIDENT did you have com- compensation benefits;
plaints or injuries that involved the same part of your body (e) a description of the injury;
claimed to have been injured in the INCIDENT? If so, for
(f) the name, ADDRESS, and telephone number of any
each state:
HEALTH CARE PROVIDER who provided services;
(a) a description of the complaint or injury; and
(b) the dates it began and ended; and (g) the case number at the Workers' Compensation
Appeals Board.
(c) the name, ADDRESS, and telephone number of each
HEALTH CARE PROVIDER whom you consulted or 12.0 Investigation—General
who examined or treated you. i I 12.1 State the name, ADDRESS, and telephone number of
each Individual:
I I 10.2 List all physical, mental, and emotional disabilities you
(a) who witnessed the INCIDENT or the events
had immediately before the INCIDENT. (You may omit
mental or emotional disabilities unless you attribute any occurring immediately before or after the INCIDENT;
mental or emotional injury to the INCIDENT.) (b) who made any statement at the scene of the
INCIDENT;
I I 10.3 At any time after the INCIDENT, did you sustain injuries (c) who heard any statements made about the INCIDENT
of the kind for which you are now claiming damages? If so, by any individual at the scene; and
for each incident giving rise to an injury state:
(d) who YOU OR ANYONE ACTING ON YOUR
(a) the date and the place It occurred; BEHALF claim has knowledge of the INCIDENT
(except for expert witnesses covered by Code of Civil
(b) the name, ADDRESS, and telephone number of any Procedure section 2034).
other PERSON involved;
I I 12.2 Have YOU OR ANYONE ACTING ON YOUR
(c) the nature of any injuries you sustained; BEHALF interviewed any individual conceming the
(d) the name, ADDRESS, and telephone number of each INCIDENT? If so, for each individual state:
HEALTH CARE PROVIDER who you consulted or who (a) the name, ADDRESS, and telephone number of the
examined or treated you; and Individual Interviewed;
(b) the date of the interview; and
(e) the nature of the treatment and its duration.
(c) the name, ADDRESS, and telephone number of the
11.0 Other Claims and Previous Claims PERSON who conducted the Interview.
I I 12.3 Have YOU OR ANYONE ACTING ON YOUR
11.1 Except for this action, in the past 10 years have you
BEHALF obtained a written or recorded statement from
filed an action or made a written claim or demand for
any individual conceming the INCIDENT? If so, for each
compensation for your personal injuries? If so, for each
statement state:
action, claim, or demand state:
(a) the name, ADDRESS, and telephone number of the
(a) the date, time, and place and location (closest street individual from whom the statement was obtained;
ADDRESS or intersection) of the INCIDENT giving rise (b) the name, ADDRESS, and telephone number of the
to the action, claim, or demand; individual who obtained the statement;
(b) the name, ADDRESS, and telephone number of each (c) the date the statement was obtained; and
PERSON against whom the claim or demand was (d) the name, ADDRESS, and telephone number of each
made or the action filed; PERSON who has the original statement or a copy.
OISC-001 [Rev. January 1, 2008] Page 5 of 8
FORM INTERROGATORIES—GENERAL
DISC-001
12.4 Do YOU OR ANYONE ACTING ON YOUR BEHALF 13.2 Has a written report been prepared on the
know of any photographs, films, or videotapes depicting any surveillance? If so, for each written report state:
place, object, or individual conceming the INCIDENT or (a) the title;
plaintiffs injuries? If so, state: (b) the date;
(a) the number of photographs or feet of film or videotape; (c) the name, ADDRESS, and telephone number of the
(b) the places, objects, or persons photographed, filmed, Individual who prepared the report; and
or videotaped; (<^) 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
r n 14.1 Do YOU OR ANYONE ACTING ON YOUR BEHALF
(d) the name, ADDRESS, and telephone number of the contend that any PERSON involved in the INCIDENT
individual taking the photographs, films, or videotapes; violated any statute, ordinance, or regulation and that the
and violation was a legal (proximate) cause of the INCIDENT?
(e) the name, ADDRESS, and telephone number of each If so, identify the name, ADDRESS, and telephone number
PERSON who has the original or a copy of the of each PERSON and the statute, ordinance, or regulation
photographs, films, or videotapes. that was violated.
12.5 Do YOU OR ANYONE ACTING ON YOUR BEHALF I I 14.2 Was any PERSON cited or charged with a violation of
know of any diagram, reproduction, or model of any place or any statute, ordinance, or regulation as a result of this
thing (except for items developed by expert witnesses INCIDENT? If so, for each PERSON state:
covered by Code of Civil Procedure sections 2034.210- (a) the name, ADDRESS, and telephone number of the
2034.310) conceming the INCIDENT? If so, for each item PERSON;
state: (b) the statute, ordinance, or regulation allegedly violated;
(a) the type (i.e., diagram, reproduction, or model); (c) whether the PERSON entered a plea in response to
(b) the subject matter; and the citation or charge and, if so, the plea entered; and
(c) the name, ADDRESS, and telephone number of each (d) the name and ADDRESS of the court or administrative
PERSON who has it. agency, names of the parties, and case number.
12.6 Was a report made by any PERSON conceming the 15.0 Denials and Special or Affirmative Defenses
INCIDENT? If so, state: I 1 15.1 Identify each denial ofa material allegation and each
(a) the name, title, identification number, and employer of special or affirmative defense in your pleadings and for
each:
the PERSON who made the report;
(a) state all facts upon which you base the denial or
(b) the date and type of report made;
special or affirmative defense;
(c) the name, ADDRESS, and telephone number of the
(b) state the names, ADDRESSES, and telephone
PERSON for whom the report was made; and numbers of all PERSONS who have knowledge of
(d) the name, ADDRESS, and telephone number of each those facts; and
PERSON who has the original or a copy of the report. (c) Identify all DOCUMENTS and other tangible things
12.7 Have YOU OR ANYONE ACTING ON YOUR that support your denial or special or affirmative
BEHALF inspected the scene of the INCIDENT? If so, for defense, and state the name, ADDRESS, and
each inspection state: telephone number of the PERSON who has each
(a) the name, ADDRESS, and telephone number ofthe DOCUMENT.
individual making the inspection (except for expert 16.0 Defendant's Contentions—Personal Injury
witnesses covered by Code of Civil Procedure I I 16.1 Do you contend that any PERSON, other than you or
sections 2034.210-2034.310); and plaintiff, contributed to the occurrence ofthe INCIDENT or
the injuries or damages claimed by plaintiff? If so, for each
(b) the date of the inspection.
PERSON:
13.0 Investigation—Surveillance (a) state the name, ADDRESS, and telephone number of
13.1 Have YOU OR ANYONE ACTING ON YOUR BEHALF the PERSON;
conducted surveillance of any individual involved in the (b) state all facts upon which you base your contention;
INCIDENT or any party to this action? If so, for each (c) state the names, ADDRESSES, and telephone
surveillance state: numbers of all PERSONS who have knowledge of the
(a) the name, ADDRESS, and telephone number of the facts; and
Individual or party; (d) identify all DOCUMENTS and other tangible things
that support your contention and state the name,
(b) the time, date, and place of the surveillance;
ADDRESS, and telephone number ofthe PERSON
(c) the name, ADDRESS, and telephone number of the who has each DOCUMENT or thing.
individual who conducted the surveillance; and I I 16.2 Do you contend that plaintiff was not injured in the
(d) the name, ADDRESS, and telephone number of each INCIDENT? If so:
PERSON who has the original or a copy of any (a) state all facts upon which you base your contention;
surveillance photograph, film, or videotape. (b) state the names, ADDRESSES, and telephone
numbers of all PERSONS who have knowledge of the
facts; and
(c) identify all DOCUMENTS and other tangible things
that support your conten
Preview
JOSHUA S. FALAKASSA (SBN: 295045) FlLEO/EiOOl FALAKASSA LAW, P C. 2 1901 Avenue ofthe Stars Suite # 450 Los Angeles, Califomiia 90067 JUN 2 9 2022 3 Tel.: (818) 456-6168; Fax: (888) 505-0868 By: E. Macdonald 4 Email: josh@falakassalaw.com Deputy Clerk 5 ARASH S. KHOSROWSHAHI (SBN: 293246) LIBERTY MAN LAW, P.C. 6 1010 F Street, Ste, 300 Sacramento, Califomia 95814 7 Tel.: (916) 573-0469; Fax: (866) 700-0787 Email: ash@libertymanlaw.com 8 Attomeys for Plaintiff, 9 SAJIDA ZAMAN 10 SUPERIOR COURT OF CALIFORNIA 11 COUNTY OF SACRAMENTO 12 13 SAJIDA ZAMAN, CASE NO.: 34-2019-00252121 RESERVATION ID: 2656706 14 Plaintiff, DECLARATION OF ARASH S. 15 vs. KHOSROWSHAHI IN SUPPORT OF MOTION TO COMPEL DISCOVERY 16 LIQUI-BOX CORPORATION, and DOES RESPONSES AS TO FORM through 20, inclusive. INTERROGATORIES-GENERAL, SET 17 TWO (2), AND MONETARY Defendants. SANCTIONS 18 Concurrently filed with Plaintiff's Motion to 19 Deem Requests for Admissions Admitted and Monetary Sanctions 20 Date: September 1, 2022'ry ^ 21 Time: 1:30pm li % i^'AA 22 Dept.: 53 Trial Date: September 12, 2022 23 1, ARASH KHOSROWSHAHI, declare as follows: 24 1. I am an attomey licensed to practice law in the State of Califomia. My State Bar Numbei 25 is 293246. 26 2. I represent Plaintiff Sajida Zaman ("Plaintiff) in the above-entitled action. I have 27 knowledge of the facts stated herein and can testify competently thereto. 28 DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT 1 of 3 1 3. On May 27, 2022 I on behalf of Plaintiff served her second set of Form Interrogatories- 2 General propounded against Defendant via email. (Attached as Exhibit A is a tme and 3 correct copy of Plaintiff Sajida Zaman's Form Interrogatories—General, Set Two to 4 Defendant [hereinafter "FROGs"]; attached as Exhibit B is a tme and correct copy of 5 Plaintiffs Proof of Service, showing a service date of May 27, 2022 arid executed May 31, 6 2022.) The FROGs were concurrently served with Plaintiffs Requests for Admissions to 7 Defendant Liqui-Box Corporation (Set One) ("RFAs") (See Exhibit B), and contained a 8 single interrogatory. No. 17.1, which required the Defendant to provide all facts, witnesses, 9 and documents in support of any denial or qualified admission to the RFAs. (See Exhibit 10 A), 11 4. As of this writing Defendant did not serve any objections or responses to the FROGs. This 12 was despite the fact that Defendant did serve objections on concurrently-served discovery 13 requests from the same email the FROGs and RFAs were served in. (See Exhibit B.) 14 5. I am a graduate of the University of Califomia, Berkeley School of Law ("Boalt Hall"), a 15 Top 14 law school. I further graduated with a Bachelor of Science in Mathematics (Honors) 16 and a Bachelor of Arts in Philosophy (Highest Honors) from the University of Califomia, 17 Davis in 2009. I mn a solo practice in Sacramento, Califomia, and have been practicing 18 law since December 2013.1 primarily handle unlimited civil litigation cases in employment 19 law, which include class-action wage-and-hour cases as well as wrongful termination 20 cases. I practice throughout the State of Califomia, having litigated cases successfiilly in 21 the greater Sacramento Area, the Bay Area, and the greater Los Angeles area. I have also 22 negotiated six-figure/seven-figure settlements for class-action wage-and-hour matters as 23 well as six-figure settlements for wrongful termination matters. I was selected as a Super 24 Lawyer Rising Star in Northem Califomia in 2020 and 2021, a distinction that is reserved 25 for the top 2.5% of lawyers practicing less than 10 years. For these reasons, I believe an 26 hourly rate of $500 is a reasonable hourly rate. 27 28 DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT 2 of 3 6. I spent 1.5 hours researching and drafting this instant Motion and related documents herein, 2 resulting in $750.00 in reasonable attomey's fees. Further, Plaintiff incurs a $60 motion 3 filing fee. I therefore respectfully request sanctions in the amount of $810.00 for reasonable 4 costs and attomey's fees. 5 I declare under penalty of perjury under the laws of the State of Califomia that the 6 foregoing is tme and correct. 7 Dated: June 29, 2022 8 9 Arash S. Khosrowshahi 10 Attomey for Plaintiff Sajida Zaman 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT 3 of 3 EXHIBIT A DISC-001 ATTORNEY OR PARTY WITHOUT ATTORNEY (Nama, State Bar number, and address): ARASH S. KHOSROWSHAHI (SBN: 293246) LIBERTY MAN LAW, P.C, 1010 F Street, Ste. 300, Sacramento, CA 95814 TELEPHONENO.: 916.573.0469 FAX NO. IOptional): 866.700.0787 E-MAILADDRESS IOptional): ash(ajlibertvmanlaw.com ATTORNEY FOR (Name): SAJ1 DA ZAMAN SUPERIOR COURT OF CALIFORNIA, COUNTY OF SACRAMENTO SHORT TITLE OF CASE: ZAMAN V. LIQUI-BOX CORPORATION, et al. FORM INTERROGATORIES—GENERAL CASE NUMBER: 34-2019-00252121 A s k i n g Party: LIQUI-BOX CORPORATION A n s w e r i n g Party: SAJIDA ZAMAN Set No.: 2 Sec. 1. Instructions to All Parties (c) Each answer must.be as complete and straightforward as (a) Interrogatories are written questions prepared by a party to an the infonmation reasonably available to you, including the action that are sent to any other party in the action to be infonmation possessed by your attomeys or agents, permits. answered under oath. The interrogatories below are form If an Interrogatory cannot be answered completely, answer it interrogatories approved for use in civil cases. to the extent possible. (b) For time limitations, requirements for service on other parties, (d) If you do not have enough personal knowledge to fully and other details, see Code of Civil Procedure sections answer an Interrogatory, say so, but make a reasonable and 2030.010-2030.410 and the cases construing those sections. good faith effort to get the information by asking other (c) These form interrogatories do not change existing law persons or organizations, unless the information is equally relating to interrogatories nor do they affect an answering available to the asking party. party's right to assert any privilege or make any objection. (e) Whenever an interrogatory may be answered by referring to Sec. 2. Instructions to the Asking Party a document, the document may be attached as an exhibit to (a) These Interrogatories are designed for optional use by parties the response and referred to in the response. If the In unlimited civil cases where the amount demanded exceeds document has more than one page, refer to the page and $25,000. Separate interrogatories, Fonm Interrogatories— section where the answer to the inten-ogatory can be found. Limited Civil Cases (Economic Litigation) (fomi DISC-004), which have no subparts, are designed for use in limited civil (0 Whenever an address and telephone number for the same person are requested in more than one Interrogatory, you cases where the amount demanded is $25,000 or less; are required to fumish them in answering only the first however, those interrogatories may also be used in unlimited Interrogatory asking for that information. civil cases. (b) Check the box next to each intenrogatory that you want the (g) If you are asserting a privilege or making an objection to an answering party to answer. Use care In choosing those interrogatory, you must specifically assert the privilege or Interrogatories that are applicable to the case. state the objection in your written response. (c) You may insert your own definition of INCIDENT in Section 4, (h) Your answers to these interrogatories must be verified, but only where the action arises from a course of conduct or a dated, and signed. You may wish to use the following form series of events occun-ing over a period of time. at the end of your answers: (d) The interrogatories in section 16.0, Defendant's Contentions- / declare underpenalty ofperjury under the laws ofthe State of Personal Injury, should not be used until the defendant has Califomia that the foregoing answers are true and correct. had a reasonable opportunity to conduct an investigation or discovery of plaintiffs injuries and damages. (e) Additional interrogatories may be attached. (Date) ISIGNATURE) Sec. 3. Instructions to the Answering Party Sec. 4. Definitions (a) An answer or other appropriate response must be given to Words in BOLDFACE CAPITALS in these inten-ogatories are each inten-ogatory checked by the asking party. defined as follows: (b) As a general rule, within 30 days after you are served with (a) (Check one of the following): these inten-ogatories, you must serve your responses on the I I (1) INCIDENT Includes the circumstances and asking party and serve copies of your responses on all other events surrounding the alleged accident, injury, parties to the action who have appeared. See Code of Civil or other occun-ence or breach of contract giving Procedure sections 2030.260-2030.270 for details. rise to this action or proceeding. Page < ot t form Approved for Optional Use Code of Civil Procedure, §§ Judicial Council of California FORM INTERROGATORIES—GENERAL 2030.010-2030.410,2033.710 DISC-001 [Rev. January 1, 2008] Mww.courrs.CQ.90v DISC-001 ] (2) INCIDENT means (insert your definition here or on a 1.0 Identity of Persons Answering These interrogatories separate, attached sheet labeled "Sec. 4(a)(2)"): I 1 1.1 State the name, ADDRESS, telephone number, and relationship to you of each PERSON who prepared or assisted in the preparation of the responses to these interrogatories. (Do not Identify anyone who simply typed or reproduced the responses) 2.0 General Background Information individual— (b) YOU OR ANYONE ACTING ON YOUR BEHALF includes I I 2.1 State: you, your agents, your employees, your insurance (a) your name; companies, their agents, their employees, your attomeys, (b) every name you have used in the past; and your accountants, your investigators, and anyone else acting (c) the dates you used each name. on your behalf. I I 2.2 State the date and place of your birth. (c) PERSON includes a natural person, firm, association, organization, partnership, business, trust, limited liability I I 2.3 At the time of the INCIDENT, did you have a driver's company, corporation, or public entity. license? If so state: (d) DOCUMENT means a writing, as defined in Evidence Code (a) the state or other issuing entity; , section 250, and includes the original or a copy of (b) the license number and type; handwriting, typewriting, printing, photostats, photographs, (c) the date of issuance; and electronically stored information, and every other means of (d) all restrictions. recording upon any tangible thing and form of communicating I I 2.4 At the time of the INCIDENT, did you have any other or representation, induding letters, words, pictures, sounds, or symbols, or combinations of them. permit or license for the operation of a motor vehicle? If so, state: (e) HEALTH CARE PROVIDER includes any PERSON refen-ed to in Code of Civil Procedure section 667.7(e)(3). (a) the state or other issuing entity; (f) ADDRESS means the street address, including the city, (b) the license number and type; state, and zip code. (c) the date of issuance; and (d) all restrictions. Sec. 5. Interrogatories I ~i 2.5 State: The following interrogatories have been approved by the Judicial (a) your present residence ADDRESS; Council under Code of Civil Procedure section 2033.710: (b) your residence ADDRESSES for the past five years; CONTENTS and 1.0 Identity of Persons Answering These Inten'ogatories (c) the dates you lived at each ADDRESS. 2.0General Background Information—Individual 2.6 State: 3.0General Background Information—Business Entity (a) the name, ADDRESS, and telephone number of your 4.0 Insurance present employer or place of self-employment; and 5.0//?esen/ed7 e.OPhysical, Mental, or Emotional Injuries (b) the name, ADDRESS, dates of employment, job title, 7.0 Property Damage and nature of work for each employer or self- 8.0Loss of Income or Earning Capacity employment you have had from five years before the 9.0Other Damages INCIDENT until today. 10.0 Medical History 1 I 2.7 State: ll.OOther Claims and Previous Claims (a) the name and ADDRESS of each school or other 12.0lnvestigation—General academic or vocational institution you have attended, 13.0lnvestigation—Surveillance beginning with high school; 14.0Statutory or Regulatory Violations 15.0Denials and Special or Affirmative Defenses (b) the dates you attended; 16.0 Defendant's Contentions Personal Injury (c) the highest grade level you have completed; and 17.0Responses to Request for Admissions (d) the degrees received. 18.0/Reserved7 I I 2.8 Have you ever been convicted of a felony? If so, for 19.0//?esen/ec(/ 2O.OH0W the Incident Occurred—Motor Vehicle each conviction state: 25.0/Reserved7 (a) the city and state where you were convicted; 30.0/F?ese/veai/ (b) the date of conviction; 40.0/^Resen/ecii/ (c) the offense; and 50.0Contract eO.O/Reserved/ (d) the court and case number. 70.0Unlawful Detainer [See separate form DISC-003] I I 2.9 Can you speak English with ease? If not, what lOI.OEconomic Litigation [See separate form DISC-004] language and dialect do you normally use? 200.0Employment Law [See separate fonn DISC-002] Family I I 2.10 Can you read and write English with ease? If not, Law [See separate form FL-745/ what language and dialect do you normally use? •ISC-001 [Rev. January 1, 2008] Page 2 of 8 FORM INTERROGATORIES—GENERAL DISC-001 ] 2.11 At the time of the INCIDENT were you acting as an 3.4 Are you a joint venture? If so, state: agent or employee for any PERSON? If so, state: (a) the current joint venture name; (a) the name, ADDRESS, and telephone number of that (b) all other names used by the joint venture during the PERSON: and past 10 years and the dates each was used; (b) a description of your duties. (c) the name and ADDRESS of each joint venturer; and ] 2.12 At the time of the INCIDENT did you or any other (d) the ADDRESS of the principal place of business. person have any physical, emotional, or mental disability or condition that may have contributed to the occurrence of the I I 3.5 Are you an unincorporated association? If so, state: INCIDENT? If so, for each person state: (a) the current unincorporated association name; (a) the name, ADDRESS, and telephone number; (b) all other names used by the unincorporated (b) the nature of the disability or condition; and association during the past 10 years and the dates (c) the manner in which the disability or condition each was used; and contributed to the occurrence of the INCIDENT. (c) the ADDRESS of the principal place of business. ] 2.13 Within 24 hours before the INCIDENT did you or any I I 3.6 Have you done business under a fictitious name during person involved in the INCIDENT use or take any of the the past 10 years? If so, for each fictitious name state; following substances: alcoholic beverage,.marijuana, or other drug or medication of any kind (prescription or not)? If (a) the name; so, for each person state: (b) the dates each was used; (a) the name, ADDRESS, and telephone number; (c) the state and county of each fictitious name filing; and (b) the nature or description of each substance; (d) the ADDRESS of the principal place of business. (c) the quantity of each substance used or taken; I I 3.7 Within the past five years has any public entity (d) the date and time of day when each substance was registered or licensed your business? If so, for each license used or taken; or registration: (e) the ADDRESS where each substance was used or (a) identify the license or registration; taken; (b) state the name of the public entity; and (f) the name, ADDRESS, and telephone number of each person who was present when each substance was (c) state the dates of issuance and expiration. used or taken; and 4.0 Insurance (g) the name, ADDRESS, and telephone number of any I I 4.1 At the time of the INCIDENT, was there in effect any HEALTH CARE PROVIDER who prescribed or policy of insurance through which you were or might be fumished the substance and the condition for which it insured in any manner (for example, primary, pro-rata, or was prescribed or furnished. excess liability coverage or medical expense coverage) for 3.0 General Background Information—Business Entity the damages, claims, or actions that have arisen out of the INCIDENT? If so, for each policy state: ] 3.1 Are you a corporation? If so, state: (a) the name stated in the current articles of Incorporation; (a) the kind of coverage; (b) all other names used by the corporation during the past (b) the name and ADDRESS of the insurance company; 10 years and the dates each was used; (c) the name, ADDRESS, and telephone number of each (c) the date and place of Incorporation; named insured; (d) the ADDRESS of the principal place of business; and (d) the policy number; (e) whether you are qualified to do business In California. (e) the limits of coverage for each type of coverage ] 3.2 Are you a partnership? If so, state: contained in the policy; (a) the current partnership name; (f) whether any reservation of rights or controversy or (b) all other names used by the partnership during the past coverage dispute exists between you and the 10 years and the dates each was used; insurance company; and (c) whether you are a limited partnership and, if so, under (g) the name, ADDRESS, and telephone number of the the laws of what jurisdiction; custodian of the policy. (d) the name and ADDRESS of each general partner; and I i 4.2 Are you self-insured under any statute for the (e) the ADDRESS of the principal place of business. damages, claims, or actions that have arisen out of the 3.3 Are you a limited liability company? If so, state: INCIDENT? If so, specify the statute. (a) the name stated in the current articles of organization; 5.0 [Resen/edj (b) all other names used by the company during the past 6.0 Physical, Mental, or Emotional Injuries 10 years and the date each was used; I I 6.1 Do you attribute any physical, mental, or emotional (c) the date and place of filing of the articles of injuries to the INCIDENT? (If your answer is "no," do not organization; answer interrogatories 6.2 through 6.7). (d) the ADDRESS of the principal place of business; and I I 6.2 Identify each injury you attribute to the INCIDENT and (e) whether you are qualified to do business in Califomia. the area of your body affected. OISC.001 (Rev. January 1. 2008) FORM INTERROGATORIES—GENERAL Page 3 of S DISC-001 I 6.3 Do you still have any complaints that you attribute to the (c) state the amount of damage you are claiming for INCIDENT? If so, for each complaint state: each item of property and how the amount was (a) a description; calculated; and (b) whether the complaint is subsiding, remaining the (d) if the property was sold, state the name, ADDRESS, same, or becoming worse; and and telephone number of the seller, the date of sale, and the sale price. (c) the frequency arid duration. I 6.4 Did you receive any consultation or examination (except I I 7.2 Has a written estimate or evaluation been made for any from expert witnesses covered by Code of Civil Procedure item of property referred to In your answer to the preceding sections 2034.210-2034.310) or treatment from a HEALTH inten-ogatory? If so, for each estimate or evaluation state: CARE PROVIDER for any Injury you attribute to the (a) the name, ADDRESS, and telephone number of the INCIDENT? If so, for each HEALTH CARE PROVIDER PERSON who prepared it and the date prepared; state: (b) the name, ADDRESS, and telephone number of each (a) the name, ADDRESS, and telephone number; PERSON who has a copy of it; and (b) the type of consultation, examination, or treatment (c) the amount of damage stated. provided; (c) the dates you received consultation, examination, or I I 7.3 Has any item of property referred to in your answer to treatment; and interrogatory 7.1 been repaired? If so, for each item state: (d) the charges to date. (a) the date repaired; I 6.5 Have you taken any medication, prescribed or hot, as a (b) a description of the repair; result of injuries that you attribute to the INCIDENT? If so, (c) the repair cost; for each medication state: (d) the name, ADDRESS, and telephone number of the (a) the name; PERSON who repaired it; (b) the PERSON who prescribed or furnished il; (e) the name, ADDRESS, and telephone number of the (c) the date it was prescribed or furnished; PERSON who paid for the repair. (d) the dates you began and stopped taking it; and 8.0 Loss of Income or Earning Capacity (e) the cost to date. I 6.6 Are there any other medical services necessitated I I 8.1 Do you attribute any loss of Income or earning capacity by the injuries that you attribute to the INCIDENT that to the INCIDENT? (If your answer is "no." do not answer were not previously listed (for example, ambulance, nursing, interrogatories 8.2 through 8.8). prosthetics)? If so, for each service state: I I 8.2 State: (a) the nature; (a) the nature of your work; (b) the date; (b) your job title at the time of the INCIDENT; and (c) the cost; and (c) the date your employment began. (d) the name, ADDRESS, and telephone number 8.3 State the last date before the INCIDENT that you of each provider. worked for compensation. I 6.7 Has any HEALTH CARE PROVIDER advised that you may require future or additional treatment for any injuries 8.4 State your monthly Income at the time of the INCIDENT that you attribute to the INCIDENT? If so, for each injury and how the amount was calculated. state: 8.5 State the date you retumed to work at each place of (a) the name and ADDRESS of each HEALTH CARE employment following the INCIDENT. PROVIDER; 8.6 State the dates you did not work and for which you lost (b) the complaints for which the treatment was income as a result of the INCIDENT. advised; and I I 8.7 State the total income you have lost to date as a result (c) the nature, duration, and estimated cost of of the INCIDENT and how the amount was calculated. the treatment. .0 Property Damage 8.8 Will you lose income in the future as a result of the INCIDENT? If so. state: I 7.1 Do you attribute any loss of or damage to a vehicle or other property to the INCIDENT? If so, for each item of (a) the facts upon which you base this contention; property: (b) an estimate of the amount; (a) describe the property; (c) an estimate of how long you will be unable to work; (b) describe the nature and location of the damage to the and property; (d) how the claim for future income is calculated. DISC-001 [Rev. January 1, 200BJ Page 4 of 8 FORM INTERROGATORIES—GENERAL DISC-001 9.0 Other Damages (c) the court, names of the parties, and case number of any action filed; I I 9.1 Are there any other damages that you attribute to the (d) the name, ADDRESS, and telephone number of any INCIDENT? If so, for each item of damage state: attorney representing you; (a) the nature; (e) whether the claim or action has been resolved or is pending; and (b) the date it occun-ed; (f) a description of the Injury. (c) the amount; and 11.2 In the past 10 years have you made a written claim or (d) the name, ADDRESS, and telephone number of each demand for workers' compensation benefits? If so, for each PERSON to whom an obligation was Incuri-ed. claim or demand state: (a) the date, time, and place of the INCIDENT giving rise 9.2 Do any DOCUMENTS support the existence or amount to the claim; of any Item of damages claimed in interrogatory 9.1? If so, (b) the name, ADDRESS, and telephone number of your describe each document and state the name, ADDRESS, employer at the time of the injury; and telephone number of the PERSON who has each DOCUMENT. (c) the name, ADDRESS, and telephone number ofthe workers' compensation insurer and the claim nurnber; 10.0 Medical History (d) the period of time during which you received workers' I I 10.1 At any time before the INCIDENT did you have com- compensation benefits; plaints or injuries that involved the same part of your body (e) a description of the injury; claimed to have been injured in the INCIDENT? If so, for (f) the name, ADDRESS, and telephone number of any each state: HEALTH CARE PROVIDER who provided services; (a) a description of the complaint or injury; and (b) the dates it began and ended; and (g) the case number at the Workers' Compensation Appeals Board. (c) the name, ADDRESS, and telephone number of each HEALTH CARE PROVIDER whom you consulted or 12.0 Investigation—General who examined or treated you. i I 12.1 State the name, ADDRESS, and telephone number of each Individual: I I 10.2 List all physical, mental, and emotional disabilities you (a) who witnessed the INCIDENT or the events had immediately before the INCIDENT. (You may omit mental or emotional disabilities unless you attribute any occurring immediately before or after the INCIDENT; mental or emotional injury to the INCIDENT.) (b) who made any statement at the scene of the INCIDENT; I I 10.3 At any time after the INCIDENT, did you sustain injuries (c) who heard any statements made about the INCIDENT of the kind for which you are now claiming damages? If so, by any individual at the scene; and for each incident giving rise to an injury state: (d) who YOU OR ANYONE ACTING ON YOUR (a) the date and the place It occurred; BEHALF claim has knowledge of the INCIDENT (except for expert witnesses covered by Code of Civil (b) the name, ADDRESS, and telephone number of any Procedure section 2034). other PERSON involved; I I 12.2 Have YOU OR ANYONE ACTING ON YOUR (c) the nature of any injuries you sustained; BEHALF interviewed any individual conceming the (d) the name, ADDRESS, and telephone number of each INCIDENT? If so, for each individual state: HEALTH CARE PROVIDER who you consulted or who (a) the name, ADDRESS, and telephone number of the examined or treated you; and Individual Interviewed; (b) the date of the interview; and (e) the nature of the treatment and its duration. (c) the name, ADDRESS, and telephone number of the 11.0 Other Claims and Previous Claims PERSON who conducted the Interview. I I 12.3 Have YOU OR ANYONE ACTING ON YOUR 11.1 Except for this action, in the past 10 years have you BEHALF obtained a written or recorded statement from filed an action or made a written claim or demand for any individual conceming the INCIDENT? If so, for each compensation for your personal injuries? If so, for each statement state: action, claim, or demand state: (a) the name, ADDRESS, and telephone number of the (a) the date, time, and place and location (closest street individual from whom the statement was obtained; ADDRESS or intersection) of the INCIDENT giving rise (b) the name, ADDRESS, and telephone number of the to the action, claim, or demand; individual who obtained the statement; (b) the name, ADDRESS, and telephone number of each (c) the date the statement was obtained; and PERSON against whom the claim or demand was (d) the name, ADDRESS, and telephone number of each made or the action filed; PERSON who has the original statement or a copy. OISC-001 [Rev. January 1, 2008] Page 5 of 8 FORM INTERROGATORIES—GENERAL DISC-001 12.4 Do YOU OR ANYONE ACTING ON YOUR BEHALF 13.2 Has a written report been prepared on the know of any photographs, films, or videotapes depicting any surveillance? If so, for each written report state: place, object, or individual conceming the INCIDENT or (a) the title; plaintiffs injuries? If so, state: (b) the date; (a) the number of photographs or feet of film or videotape; (c) the name, ADDRESS, and telephone number of the (b) the places, objects, or persons photographed, filmed, Individual who prepared the report; and or videotaped; (<^) 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 r n 14.1 Do YOU OR ANYONE ACTING ON YOUR BEHALF (d) the name, ADDRESS, and telephone number of the contend that any PERSON involved in the INCIDENT individual taking the photographs, films, or videotapes; violated any statute, ordinance, or regulation and that the and violation was a legal (proximate) cause of the INCIDENT? (e) the name, ADDRESS, and telephone number of each If so, identify the name, ADDRESS, and telephone number PERSON who has the original or a copy of the of each PERSON and the statute, ordinance, or regulation photographs, films, or videotapes. that was violated. 12.5 Do YOU OR ANYONE ACTING ON YOUR BEHALF I I 14.2 Was any PERSON cited or charged with a violation of know of any diagram, reproduction, or model of any place or any statute, ordinance, or regulation as a result of this thing (except for items developed by expert witnesses INCIDENT? If so, for each PERSON state: covered by Code of Civil Procedure sections 2034.210- (a) the name, ADDRESS, and telephone number of the 2034.310) conceming the INCIDENT? If so, for each item PERSON; state: (b) the statute, ordinance, or regulation allegedly violated; (a) the type (i.e., diagram, reproduction, or model); (c) whether the PERSON entered a plea in response to (b) the subject matter; and the citation or charge and, if so, the plea entered; and (c) the name, ADDRESS, and telephone number of each (d) the name and ADDRESS of the court or administrative PERSON who has it. agency, names of the parties, and case number. 12.6 Was a report made by any PERSON conceming the 15.0 Denials and Special or Affirmative Defenses INCIDENT? If so, state: I 1 15.1 Identify each denial ofa material allegation and each (a) the name, title, identification number, and employer of special or affirmative defense in your pleadings and for each: the PERSON who made the report; (a) state all facts upon which you base the denial or (b) the date and type of report made; special or affirmative defense; (c) the name, ADDRESS, and telephone number of the (b) state the names, ADDRESSES, and telephone PERSON for whom the report was made; and numbers of all PERSONS who have knowledge of (d) the name, ADDRESS, and telephone number of each those facts; and PERSON who has the original or a copy of the report. (c) Identify all DOCUMENTS and other tangible things 12.7 Have YOU OR ANYONE ACTING ON YOUR that support your denial or special or affirmative BEHALF inspected the scene of the INCIDENT? If so, for defense, and state the name, ADDRESS, and each inspection state: telephone number of the PERSON who has each (a) the name, ADDRESS, and telephone number ofthe DOCUMENT. individual making the inspection (except for expert 16.0 Defendant's Contentions—Personal Injury witnesses covered by Code of Civil Procedure I I 16.1 Do you contend that any PERSON, other than you or sections 2034.210-2034.310); and plaintiff, contributed to the occurrence ofthe INCIDENT or the injuries or damages claimed by plaintiff? If so, for each (b) the date of the inspection. PERSON: 13.0 Investigation—Surveillance (a) state the name, ADDRESS, and telephone number of 13.1 Have YOU OR ANYONE ACTING ON YOUR BEHALF the PERSON; conducted surveillance of any individual involved in the (b) state all facts upon which you base your contention; INCIDENT or any party to this action? If so, for each (c) state the names, ADDRESSES, and telephone surveillance state: numbers of all PERSONS who have knowledge of the (a) the name, ADDRESS, and telephone number of the facts; and Individual or party; (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, (b) the time, date, and place of the surveillance; ADDRESS, and telephone number ofthe PERSON (c) the name, ADDRESS, and telephone number of the who has each DOCUMENT or thing. individual who conducted the surveillance; and I I 16.2 Do you contend that plaintiff was not injured in the (d) the name, ADDRESS, and telephone number of each INCIDENT? If so: PERSON who has the original or a copy of any (a) state all facts upon which you base your contention; surveillance photograph, film, or videotape. (b) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (c) identify all DOCUMENTS and other tangible things that support your conten