Preview
.
Leigh Rodriguez, CSB#152227
Attomey at Law
101 Camino Aguajito, Suite 1
Monterey, CA 93940
(831) 655-9500
Attorney for Carrie Griffin, Peter Curatolo,
and Kathleen Hannah
SUPERIOR COURT OF CALIFORNIA
COUNTY OF MONTEREY
10
11 Carrie Griffin, et al., Case #23CV002873
12 Plaintiffs, EXHIBITS TO MOTION TO COMPEL
RESPONSES TO FORM
13 Vv. INTERROGATORIES, TO COMPEL
RESPONSES TO DEMAND FOR
14 Michael Leonard, et al., PRODUCTION OF DOCUMENTS AND
OTHER TANGIBLE THINGS, TO
15 Defendants. HAVE REQUESTS FOR ADMISSIONS
DEEMED ADMITTED
16
Date: May 24, 2024
17 Time: 8:30 a.m.
Department: 15
18
19
20
21
22
23
24
25
26
Griffin v. Leonard
27 Monterey County Superior Court case #23CV002873
Exhibit List
28 April 2004 ‘
a 4 &
Griffin v. Leonard
Monterey County Superior Court case #23CV002873
Exhibit 1
DISC-001]
ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER:
vame’-Leigh Rodriguez, CSB#152227
rinmname: “Leigh Rodriguez, Attorney at Law
street appress: 101 Camino Aguajito, Suite 1
ery: Montere: stare: CA. zip cope: 93940
‘TELEPHONE NI (831) 655-9500 FAXNO.:
EMAIL ADDRESS:
ATTORNEY FOR (name): plaintiffs
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Monterey
Monterey Branch
SHORT TITLE OF CASE:
Griffin. et al. v. Leonard, et al.
FORM INTERROGATORIES—GENERAL CASE NUMBER:
Asking Party: Carrie Griffin 23CV002873
Answering Party: Michael Leonard
Set No. One
Sec. 1. Instructions to All Parties ©) Each answer must be as complete and straightforward
(a) Interrogatories are written questions prepared by a party as the information reasonably available to you, including the
to an action that are sent to any other party in the action to be information possessed by your attorneys or agents, permits. If
answered under oath. The interrogatories below are form an interrogatory cannot be answered completely, answer it to
interrogatories approved for use in civil cases. the extent possible.
(b) For time limitations, requirements for service on other () If you do not have enough personal knowledge to fully
parties, and other details, see Code of Civil Procedure answer an interrogatory, say so, but make a reasonable and
sections 2030.010-2030.410 and the cases construing those good faith effort to get the information by asking other persons
sections. or organizations, unless the information is equally available to
© These form interragatories de not change existing law the asking party.
relating to interrogatories nor do they affect an answering @) Whenever an interrogatory may be answered by
party's right to assert any privilege or make any objection. referring to a document, the document may be attached as an
Sec. . Instructions to the Asking Party exhibit to the response and referred to in the response, If the
@ These interrogatories are designed for optional use by document has more than one page, refer to the page and
parties in unlimited civil cases where the amount demanded section where the answer to the interrogatory can be found.
exceeds $35,000. Separate interrogatories, Form ® Whenever an address and telephone number for the
interrogatories-Limited Civil Cases (Economic Litigation} same person are requested in more than one interrogatory,
(form DISC-004), which have no subparts, are designed for you are required to furnish them in answering only the first
use in limited civil cases where the amount demanded is interrogatory asking for that information.
$35,000 or less; however, those interrogatories may also be @) If you are asserting a privilege or making an objection to
used in unlimited civil cases. an interrogatory, you must specifically assert the privilege or
(b) Check the box next to each interrogatory that you want state the objection in your written response.
the answering party to answer. Use care in choosing those (h) Your answers to these interrogatories must be verified,
interrogatories that are applicable to the case. dated, and signed. You may wish to use the following form at
©) You may insert your own definition of INCIDENT in the end of your answers:
Section 4, but only where the action arises from a course of } declare under penaity of perjury under the laws of the
conduct or a series of events occurring over a period of time. State of Califomia that the foregoing answers are true and
@ The interrogatories in section 16.0, Defendant's correct.
Contentions-Personal Injury, should not be used until the
defendant has had a reasonable opportunity to conduct an (Date) (SIGNATURE)
investigation or discovery of plaintiff's injuries and damages.
(e) Additional interrogatories may be attached.
Sec. 4. Definitions
Words in BOLDFACE CAPITALS in these interrogatories are
Sec. 3. Instructions to the Answering Party
defined as follows:
(a) An answer or other appropriate response must be
given to each interrogatory checked by the asking party. (a) (Check one of the following):
(b) As a general rule, within 30 days after you are served (WD (1) INCIDENT includes the circumstances and
with these interrogatories, you must serve your responses on events surrounding the alleged accident, injury, or
the asking party and serve copies of your responses on all other occurrence or breach of contract giving rise to
other parties to the action who have appeared. See Code of this action or proceeding.
Civil Procedure sections 2030.260-2030.270 for details.
Page 1 of8
Form, roved for Optional Use FORM INTERROGATORIES—GENERAL vil Procedure,
slusliciat -auncil of California
001 [Rev. January 1, 20241 Cab CEB
com [IslEssential ss 2005102805.pcourls.ca.gov
(416, 2033.71
Griffin, Carrie
DISC-001
(2) (2) INCIDENT means (insert your definition here or 1.0 Identity of Persons Answering These Interrogatories
on a separate, attached sheet labeled “Sec.
1.1. State the name, ADDRESS, telephone number, and
4lay(2)"): 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 24 State:
includes you, your agents, your employees, your insurance
companies, their agents, their employees, your altorneys, your (a) your name;
accountants, your investigators, and anyone else acting on (b) every name you have used in the past; and
your behalf. (©) the dates you used each name.
() PERSON includes a natural person, firm, association, 22 State the date and place of your birth.
organization, partnership, business, trust, limited liability
23 At the time of the INCIDENT, did you have a driver's
company, corporation, or public entity.
license? If so state:
(@) DOCUMENT means a writing, as defined in Evidence
(a) the state or other issuing entity;
Code section 250, and includes the original or a copy of
(b) the license number and type;
handwriting, typewriting, printing, photostats, photographs,
(©) 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
or representation, including letters, words, pictures, sounds, or
2.4 Atthe time of the INCIDENT, did you have any other
permit or license for the operation of a motor vehicle? If so,
symbols, or combinations of them.
state:
(e) HEALTH CARE PROVIDER includes any PERSON
referred to in Code of Civit Procedure section 667.7(e)(3). @ the state or other issuing entity;
® ADDRESS means the street address, including the city, (b) the license number and type;
state, and zip code. © the date of issuance; and
(d) all restrictions.
Sec. 5. Interrogatories
The following interrogatories have been approved by the Judicial
25 State:
Council under Code of Civil Procedure section 2033.710: @ your present residence ADDRESS;
(b) your residence ADDRESSES for the past five years;
CONTENTS and
1.0 Identity of Persons Answering These Interrogatories (©) the dates you lived at each ADDRESS.
2.0 General Background Information—Individual
26 State:
3.0 General Background Information—Business Entity
4.0 Insurance fa) the name, ADDRESS, and telephone number of your
present employer or place of self-employment; and
5.0 [Reserved]
6.0 Physical, 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-
employment you have had from five years before the
8.0 Loss of Income or Earning Capacity
INCIDENT until today.
9.0 Other Damages
10.0 Medical History Wy 27 State:
11.0 Other Claims and Previous Claims (@) the name and ADDRESS of each school or other
12.0 Investigation—General academic or vocational institution you have attended,
13.0 Investigation—Surveillance beginning with high school;
14.0 Statutory or Regulatory Violations (b) the dates you attended;
15.0 Denials and Special or Affirmative Defenses {c) the highest grade level you have completed; and
16.0 Defendant's Contentions Personal Injury {d) the degrees received.
17.0 Responses to Request for Admissions
18.0 [Reserved] 2.8 Have you ever been convicted of a felony? If so, for
19.0 [Reserved] each conviction state:
20.0 How the Incident Occurred - Motor Vehicle @ the city and state where you were convicted;
25.0 [Reserved] (b) the date of conviction;
30.0 [Reserved] (c) the offense; and
40.0 [Reserved] (@) the court and case number.
50.0 Contract 29 Can you speak English with ease? If not, what
60.0 [Reserved] language and dialect do you normally use?
70.0 Unlawful Detainer [See separate form DISC-003]
101.0 Economic Litigation [See separate form DISC-004] [MR 2.10 Can you read and write English with ease? If not,
200.0 Employment Law [See separate form DISC-002] Family what language and dialect do you normally use?
Law [See separate form FL-145]
DISC-001 [Rev. Jonuary
1, 2024] CEES]Essential FORM INTERROGATORIES—GENERAL Pago
2 of 8
ceb,com | {i)Forms: Griffin, Carrie
DISC-001
2.11 At the time of the INCIDENT were you acting as an fj 34 Are you a joint venture? If so, state:
agent or employee for any PERSON? If so, state: (@) 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. () the name and ADDRESS of each joint venture; and
2.12 At the time of the INCIDENT did you or any other qd) the ADDRESS of the principal place of business.
person have any physical, emotional, or mental disability or O35 Are you an unincorporated association? If so, state:
condition that may have contributed to the occurrence of the @ the current unincorporated association name;
INCIDENT? If so, for each person state: (b) all other names used by the unincorporated association
(a) the name, ADDRESS, and telephone number; during the past 10 years and the dates each was used;
(b) the nature of the disability or condition; and and
(c) the manner in which the disability or condition (c)_ the ADDRESS of the principal piace of business.
contributed to the occurrence of the INCIDENT.
CU 3.6 Have you done business under a fictitious name during
2.13 Within 24 hours before the INCIDENT did you or any
the past 10 years? If so, for each fictitious name state:
person involved in the INCIDENT use or take any of the
(a) the name;
following substances: alcoholic beverage, marijuana, or (b) the dates each was used;
other drug or medication of any kind (prescription or not)? If
(c) the state and county of each fictitious name filing; and
so, for each person state:
(d) the ADDRESS of the principal place of business.
(a) the name, ADDRESS, and telephone number;
(b) the nature or description of each substance; (J 3.7 Within the past five years has any public entity
() the quantity of each substance used or taken; registered or licensed your business? If so, for each
(@) the date and time of day when each substance was used license or registration:
or taken; @ identify the license or registration;
(e) the ADDRESS where each substance was used or (b) state the name of the public entity; and
taken; (c)_ state the dates of issuance and expiration.
a the name, ADDRESS, and telephone number of each
4.0 Insurance
person who was present when each substance was used
4.1 At the time of the INCIDENT, was there in effect any
or taken; and
policy of insurance through which you were or might be
(9) the name, ADDRESS, and telephone number of any
insured in any manner (for example, primary, pro-rata, or
HEALTH CARE PROVIDER who prescribed or furnished
excess liability coverage or medical expense coverage) for
the substance and the condition for which it was
the damages, claims, or actions that have arisen out of the
prescribed or furnished.
INCIDENT? If so, for each policy state:
3.0 General Background Information—Business Entity @ the kind of coverage;
(31 Are you a corporation? If so, state: (b) the name and ADDRESS of the insurance company;
(a) the name stated in the current articles of incorporation; ©) the name, ADDRESS, and telephone number of each
(b) all other names used by the corporation during the past named insured;
10 years and the dates each was used; qd) the policy number;
© the date and place of incorporation; ©) the limits of coverage for each type of coverage con-
(d) the ADDRESS of the principal place of business; and tained in the policy;
() whether you are qualified to do business in California. 6 whether any reservation of rights or controversy or
coverage dispute exists between you and the insurance
Cy 32 Are you a partnership? If so, state:
company; and
@) the current partnership name;
(b) all other names used by the partnership during the past (g) the name, ADDRESS, and telephone number of the
custodian of the policy.
10 years and the dates each was used;
4.2 Are you self-insured under any statute for the damages,
© whether you are a limited partnership and, if so, under
claims, or actions that have arisen out of the INCIDENT? If
the laws of what jurisdiction;
so, specify the statute.
{d) the name and ADDRESS of each general partner; and
) the ADDRESS of the principal place of business. 5.0 [Reserved]
Ci 33 Are you a limited liability company? If so, state: 6.0 Physical, Mental, or Emotional Injuries
@) the name stated in the current articles of organization;
(b) all other names used by the company during the past 10 (2) 6.1 Do you attribute any physical, mental, or emotional
years and the date each was used; injuries to the INCIDENT? (if your answer is “no,” do not
answer interrogatories 6.2 through 6.7).
(c) the date and place of filing of the articles of organization;
@) the ADDRESS of the principal place of business; and (2) 6.2. Identify each injury you attribute to the INCIDENT and
) whether you are qualified to do business in California. the area of your body affected.
DISC-001 (Rev, January 1, 2024] Page 3 of8
FORM INTERROGATORIES—GENERAL
MEICEB| Essential Griffin, Carrie
ceb.com | {Farms
DISC-001
(21 6.3 Do you still have any complaints that you attribute to (©) state the amount of damage you are claiming for each
the INCIDENT? If so, for each complaint state: item of property and how the amount was calculated; and
@ a description; (a) _ if the property was sold, state the name, ADDRESS, and
(b) whether the complaint is subsiding, remaining the same, telephone number of the seller, the date of sale, and the
or becoming worse; and sale price.
© the frequency and duration.
7.2 Has a written estimate or evaluation been made for any
Les Did you receive any consultation or examination item of property referred to in your answer to the preceding
(except from expert witnesses covered by Code of Civil interrogatory? If so, for each estimate or evaluation state:
Procedure sections 2034.210-2034.310) or treatment from a @) the name, ADDRESS, and telephone number of the
HEALTH CARE PROVIDER for any injury you attribute to PERSON who prepared it and the date prepared;
the INCIDENT? If so, for each HEALTH CARE PROVIDER ) the name, ADDRESS, and telephone number of each
state: PERSON who has a copy of it; and
(@) the name, ADDRESS, and telephone number; {c) the amount of damage stated.
(b) the type of consultation, examination, or treatment
7.3 Has any item of property referred to in your answer to
provided;
interrogatory 7.1 been repaired? If so, for each item state:
© the dates you received consultation, examination, or
treatment; and @) the date repaired;
(b) a description of the repair;
@) the charges to date.
©) the repair cost;
6.5 Have you taken any medication, prescribed or not, as a (a) the name, ADDRESS, and telephone number of the
result of injuries that you attribute to the INCIDENT? If so, PERSON who repaired it;
for each medication state: ) the name, ADDRESS, and telephone number of the
@) the name; PERSON who paid for the repair.
(b) the PERSON who prescribed or furnished it; 8.0 Loss of Income or Earning Capacity
© the date it was prescribed or furnished; (2) 8.1 Do you attribute any loss of income or earning capacity
@) the dates you began and stopped taking it; and to the INCIDENT? (if your answer is "no," do not answer
@) the cost to date, interrogatories 8.2 through 8,8).
Cy 66 Are there any other medical services necessitated by the
Cj a2 State:
injuries that you attribute to the INCIDENT that were not
previously listed (for example, ambulance, nursing, (a) the nature of your work;
prosthetics)? If so, for each service state: (b) your job title at the time of the INCIDENT; and
(a) the nature; ) the date your employment began,
(b) the date; Ci a3 State the last date before the INCIDENT that you
© the cost; and worked for compensation.
@ the name, ADDRESS, and telephone number
(J 8.4 State your monthly income at the time of the INCIDENT
of each provider.
and how the amount was calculated.
67 Has any HEALTH CARE PROVIDER advised that you
may require future or additional treatment for any injuries (C2) 8.5 State the date you returned to work at‘each place of
that you attribute to the INCIDENT? If so, for each injury employment following the INCIDENT.
state:
(J 8.6 State the dates you did not work and for which you lost
(@) the name and ADDRESS of each HEALTH CARE income as a result of the INCIDENT.
PROVIDER;
(b) the complaints for which the treatment was advised; and (CQ 8.7 State the total income you have lost to date as a result
©) the nature, duration, and estimated cost of the of the INCIDENT and how the amount was calculated.
treatment.
C) 8.8 Will you lose income in the future as a result of the
7.0 Property Damage INCIDENT? If so, state:
7.1 Do you attribute any loss of or damage to a vehicle or (@)_ the facts upon which you base this contention;
other property to the INCIDENT? If so, for each item of (b) an estimate of the amount;
property: (c) an estimate of how long you will be unable to work; and
(a) describe the property; (@)_ how the claim for future income is calculated.
(b) describe the nature and location of the damage to the
Property;
BiSC-004 (Rev. January 1, 2024] Page 4of8
FORM INTERROGATORIES—GENERAL
WECEB] Essential
ceb.com| Griffin, Carrie
DISC-001
9.0 Other Damages ©) the court, names of the parties, and case number of any
(223 9.1 Are there any other damages that you attribute to the action filed;
INCIDENT? If so, for each item of damage state: @ the name, ADDRESS, and telephone number of any
(a) the nature; attorney representing you;
(b) the date it occurred; @) whether the claim or action has been resolved or is
(c) the amount; and pending; and
{d) the name, ADDRESS, and telephone number of each 0 a description of the injury.
PERSON to whom an obligation was incurred.
11.2 In the past 10 years have you made a written claim or
C) 9.2 Do any DOCUMENTS support the existence or amount demand for workers' compensation benefits? If so, for each
of any item of damages claimed in interrogatory 9.1? If so, claim or demand state:
describe each document and state the name, ADDRESS, (@) the date, time, and place of the INCIDENT giving rise to
and telephone number of the PERSON who has each the claim;
DOCUMENT. () the name, ADDRESS, and telephone number of your
employer at the time of the injury;
10.0 Medical History
{J 10.1 At any time before the INCIDENT did you have com- © the name, ADDRESS, and telephone number of the
workers’ compensation insurer and the claim number,
plaints or injuries that involved the same part of your body
claimed to have been injured in the INCIDENT? If so, for @ the period of time during which you received workers'
compensation benefits;
each state:
(a) a description of the complaint or injury; ) a description of the injury;
(b) the dates it began and ended; and ® the name, ADDRESS, and telephone number of any
HEALTH CARE PROVIDER who provided services; and
(c) the name, ADDRESS, and telephone number of each
HEALTH CARE PROVIDER whom you consulted or (g) the case number at the Workers' Compensation Appeals
Board.
who examined or treated you.
12.0 Investigation—General
a 10.2 List all physical, mental, and emotional disabilities you
12.1 State the name, ADDRESS, and telephone number of
had immediately before the INCIDENT. (You may omit
each individual:
mental or emotional disabilities unless you attribute any
mental or emotional injury to the INCIDENT.) @) who witnessed the INCIDENT or the events occurring
immediately before or after the INCIDENT;
CJ 10.3 At any time after the INCIDENT, did you sustain (b) who made any statement at the scene of the INCIDENT;
injuries of the kind for which you are now claiming (©) who heard any statements made about the INCIDENT
damages? If so, for each incident giving rise to an injury by any individual at the scene; and
state: @) who YOU OR ANYONE ACTING ON YOUR BEHALF
{a) the date and the place it occurred; claim has knowledge of the INCIDENT (except for
{b) the name, ADDRESS, and telephone number of any expert witnesses covered by Code of Civil Procedure
other PERSON involved; section 2034).
(c) the nature of any injuries you sustained; 12.2 Have YOU OR ANYONE ACTING ON YOUR
{d) the name, ADDRESS, and telephone number of each BEHALF interviewed any individual concerning the
HEALTH CARE PROVIDER who you consulted or who
INCIDENT? If so, for each individual state:
examined or treated you; and
(e) the nature of the treatment and its duration. f@) the name, ADDRESS, and telephone number of the
individual interviewed;
11.0 Other Claims and Previous Claims (by the date of the interview; and
[-¥ 11.1 Except for this action, in the past 10 years have you (©) the name, ADDRESS, and telephone number of the
filed an action or made a written claim or demand for PERSON who conducted the interview.
compensation for your personal injuries? If so, for each
action, claim, or demand state: 12.3 Have YOU OR ANYONE ACTING ON YOUR
BEHALF obtained a written or recorded statement from any
(a) the date, time, and place and location (closest street
individual concerning the INCIDENT? If so, for each
ADDRESS or intersection) of the INCIDENT giving rise
statement state:
to the action, claim, or demand;
(b) the name, ADDRESS, and telephone number of each @ the name, ADDRESS, and telephone number of the
PERSON against whom the claim or demand was made
individual from whom the statement was obtained;
or the action filed; {b) the name, ADDRESS, and telephone number of the
individual who obtained the statement;
{c) the date the statement was obtained; and
(d) the name, ADDRESS, and telephone number of each
PERSON who has the original statement or a copy.
DISC-001 fRey, Jenuary 1, 2024] FORM INTERROGATORIES—GENERAL Page 50f8
EECEB) Essential
ceb.com | fa}Forms- Griffin, Carrie
DISC-001
() 12.4Do YOU OR ANYONE ACTING ON YOUR BEHALF 43.2 Has a written report been prepared on the
know of any photographs, films, or videotapes depicting any surveillance? lf so, for each written report state:
place, object, or individual concerning the INCIDENT or @ the title;
plaintiff's injuries? !f so, state: (b) the date;
(a) the number of photographs or feet of film or videotape; © the name, ADDRESS, and telephone number of the
(b)_ the places, objects, or persons photographed, filmed, or individual who prepared the report; and
videotaped; (d) the name, ADDRESS, and telephone number of each
() the date the photographs, films, or videotapes were PERSON who has the original or a copy.
taken; 14.0 Statutory or Regulatory Violations
(@) the name, ADDRESS, and telephone number of the 14.1 Do YOU OR ANYONE ACTING ON YOUR BEHALF
individual taking the photographs, films, or videotapes; contend that any PERSON involved in the INCIDENT
and violated any statute, ordinance, or regulation and that the
©) the name, ADDRESS, and telephone number of each violation was a legal (proximate) cause of the INCIDENT? If
PERSON who has the original or a copy of the so, identify the name, ADDRESS, and telephone number of
photographs, films, or videotapes. each PERSON and the statute, ordinance, or regulation that
was violated.
12.5Do YOU OR ANYONE ACTING ON YOUR BEHALF
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-
2034.30) conceming the INCIDENT? If so, for each item @) the name, ADDRESS, and telephone number of the
PERSON;
state:
(a) the type (.e., diagram, reproduction, or model); (b) the statute, ordinance, or regulation allegedly violated;
(b) the subject matter; and © whether the PERSON entered a plea in response to the
eltation or charge and, if so, the plea entered; and
(c) the name, ADDRESS, and telephone number of each
PERSON who has it. @ 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 15.0 Denials and Special or Affirmative Defenses.
INCIDENT? If so, state: (2) 15.1 Identify each denial of a material allegation and each
@ 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 special
(b) the date and type of report made; or affirmative defense;
() the name, ADDRESS, and telephone number of the () state the names, ADDRESSES, and telephone numbers
PERSON for whom the report was made; and of all PERSONS who have knowledge of those facts; and
(d) the name, ADDRESS, and telephone number of each {c) identify all DOCUMENTS and other tangible things that
PERSON who has the original or a copy of the report. support your denial or special or affirmative defense, and
state the name, ADDRESS, and telephone number of
12.7 Have YOU OR ANYONE ACTING ON YOUR
the PERSON who has each DOCUMENT.
BEHALF inspected the scene of the INCIDENT? If so, for
16.0 Defendant's Contentions—Personal Injury
each inspection state:
(a) the name, ADDRESS, and telephone number of the
[J] 16.1 Do you contend that any PERSON, other than you or
plaintiff, contributed to the occurrence of the INCIDENT or
individual making the inspection (except for expert
the injuries or damages claimed by plaintiff? If so, for each
witnesses covered by Code of Civil Procedure
PERSON:
sections 2034,210-2034.310); and
(b) the date of the inspection. (@) state the name, ADDRESS, and telephone number of
the PERSON;
13.0 Investigation-Surveillance () state all facts upon which you base your contention;
13.1 Have YOU OR ANYONE ACTING ON YOUR BEHALF (c) state the names, ADDRESSES, and telephone numbers.
conducted surveillance of any individual involved in the of all PERSONS who have knowledge of the facts; and
INCIDENT or any party to this action? If so, for each sur- @ identify all DOCUMENTS and other tangible things that
veillance state: support your contention and state the name, ADDRESS,
@) the name, ADDRESS, and telephone number of the and telephone number of the PERSON who has each
individual or party; DOCUMENT or thing.
(b) the time, date, and place of the surveillance; 16.2 Do you contend that plaintiff was not injured in the
© the name, ADDRESS, and telephone number of the INCIDENT? If so:
individuat who conducted the surveillance; and (a) state all facts upon which you base your contention;
{d) the name, ADDRESS, and telephone number of each (b) state the names, ADDRESSES, and telephone numbers
PERSON who has the original or a copy of any of all PERSONS who have knowledge of the facts; and
surveillance photograph, film, or videotape. () identify all DOCUMENTS and other tangible things that
support your contention and state the name, ADDRESS,
and telephone number of the PERSON whe has each
DOCUMENT or thing.
DISC-001 [Rev. January4, 2024} FORM INTERROGATORIES—GENERAL Page Gof 8
ECEB) Essential Griffin, Carrie
ceb.com | fs]Forms:
DISC-001
(2 18.300 you contend that the injuries or the extent of the (QJ 16.8 De you contend that any of the costs of repairing the
injuries claimed by plaintiff as disclosed in discovery property damage claimed by plaintiff in discovery
proceedings thus far in this case were not caused by the proceedings thus far in this case were unreasonable? If so:
INCIDENT? If so, for each injury: {a) identify each cost item;
(@) identify it; (b) state all facts upon which you base your contention;
) state all facts upon which you base your contention; () state the names, ADDRESSES, and telephone numbers
(©) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and
of all PERSONS who have knowledge of the facts; and (@) identify all DOCUMENTS and other tangible things that
@) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS,
support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each
and telephone number of the PERSON who has each DOCUMENT or thing.
DOCUMENT or thing. [2] 16.9 Do YOU OR ANYONE ACTI
Preview
. Leigh Rodriguez, CSB#152227 Attomey at Law 101 Camino Aguajito, Suite 1 Monterey, CA 93940 (831) 655-9500 Attorney for Carrie Griffin, Peter Curatolo, and Kathleen Hannah SUPERIOR COURT OF CALIFORNIA COUNTY OF MONTEREY 10 11 Carrie Griffin, et al., Case #23CV002873 12 Plaintiffs, EXHIBITS TO MOTION TO COMPEL RESPONSES TO FORM 13 Vv. INTERROGATORIES, TO COMPEL RESPONSES TO DEMAND FOR 14 Michael Leonard, et al., PRODUCTION OF DOCUMENTS AND OTHER TANGIBLE THINGS, TO 15 Defendants. HAVE REQUESTS FOR ADMISSIONS DEEMED ADMITTED 16 Date: May 24, 2024 17 Time: 8:30 a.m. Department: 15 18 19 20 21 22 23 24 25 26 Griffin v. Leonard 27 Monterey County Superior Court case #23CV002873 Exhibit List 28 April 2004 ‘ a 4 & Griffin v. Leonard Monterey County Superior Court case #23CV002873 Exhibit 1 DISC-001] ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: vame’-Leigh Rodriguez, CSB#152227 rinmname: “Leigh Rodriguez, Attorney at Law street appress: 101 Camino Aguajito, Suite 1 ery: Montere: stare: CA. zip cope: 93940 ‘TELEPHONE NI (831) 655-9500 FAXNO.: EMAIL ADDRESS: ATTORNEY FOR (name): plaintiffs SUPERIOR COURT OF CALIFORNIA, COUNTY OF Monterey Monterey Branch SHORT TITLE OF CASE: Griffin. et al. v. Leonard, et al. FORM INTERROGATORIES—GENERAL CASE NUMBER: Asking Party: Carrie Griffin 23CV002873 Answering Party: Michael Leonard Set No. One Sec. 1. Instructions to All Parties ©) Each answer must be as complete and straightforward (a) Interrogatories are written questions prepared by a party as the information reasonably available to you, including the to an action that are sent to any other party in the action to be information possessed by your attorneys or agents, permits. If answered under oath. The interrogatories below are form an interrogatory cannot be answered completely, answer it to interrogatories approved for use in civil cases. the extent possible. (b) For time limitations, requirements for service on other () If you do not have enough personal knowledge to fully parties, and other details, see Code of Civil Procedure answer an interrogatory, say so, but make a reasonable and sections 2030.010-2030.410 and the cases construing those good faith effort to get the information by asking other persons sections. or organizations, unless the information is equally available to © These form interragatories de not change existing law the asking party. relating to interrogatories nor do they affect an answering @) Whenever an interrogatory may be answered by party's right to assert any privilege or make any objection. referring to a document, the document may be attached as an Sec. . Instructions to the Asking Party exhibit to the response and referred to in the response, If the @ These interrogatories are designed for optional use by document has more than one page, refer to the page and parties in unlimited civil cases where the amount demanded section where the answer to the interrogatory can be found. exceeds $35,000. Separate interrogatories, Form ® Whenever an address and telephone number for the interrogatories-Limited Civil Cases (Economic Litigation} same person are requested in more than one interrogatory, (form DISC-004), which have no subparts, are designed for you are required to furnish them in answering only the first use in limited civil cases where the amount demanded is interrogatory asking for that information. $35,000 or less; however, those interrogatories may also be @) If you are asserting a privilege or making an objection to used in unlimited civil cases. an interrogatory, you must specifically assert the privilege or (b) Check the box next to each interrogatory that you want state the objection in your written response. the answering party to answer. Use care in choosing those (h) Your answers to these interrogatories must be verified, interrogatories that are applicable to the case. dated, and signed. You may wish to use the following form at ©) You may insert your own definition of INCIDENT in the end of your answers: Section 4, but only where the action arises from a course of } declare under penaity of perjury under the laws of the conduct or a series of events occurring over a period of time. State of Califomia that the foregoing answers are true and @ The interrogatories in section 16.0, Defendant's correct. Contentions-Personal Injury, should not be used until the defendant has had a reasonable opportunity to conduct an (Date) (SIGNATURE) investigation or discovery of plaintiff's injuries and damages. (e) Additional interrogatories may be attached. Sec. 4. Definitions Words in BOLDFACE CAPITALS in these interrogatories are Sec. 3. Instructions to the Answering Party defined as follows: (a) An answer or other appropriate response must be given to each interrogatory checked by the asking party. (a) (Check one of the following): (b) As a general rule, within 30 days after you are served (WD (1) INCIDENT includes the circumstances and with these interrogatories, you must serve your responses on events surrounding the alleged accident, injury, or the asking party and serve copies of your responses on all other occurrence or breach of contract giving rise to other parties to the action who have appeared. See Code of this action or proceeding. Civil Procedure sections 2030.260-2030.270 for details. Page 1 of8 Form, roved for Optional Use FORM INTERROGATORIES—GENERAL vil Procedure, slusliciat -auncil of California 001 [Rev. January 1, 20241 Cab CEB com [IslEssential ss 2005102805.pcourls.ca.gov (416, 2033.71 Griffin, Carrie DISC-001 (2) (2) INCIDENT means (insert your definition here or 1.0 Identity of Persons Answering These Interrogatories on a separate, attached sheet labeled “Sec. 1.1. State the name, ADDRESS, telephone number, and 4lay(2)"): 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 24 State: includes you, your agents, your employees, your insurance companies, their agents, their employees, your altorneys, your (a) your name; accountants, your investigators, and anyone else acting on (b) every name you have used in the past; and your behalf. (©) the dates you used each name. () PERSON includes a natural person, firm, association, 22 State the date and place of your birth. organization, partnership, business, trust, limited liability 23 At the time of the INCIDENT, did you have a driver's company, corporation, or public entity. license? If so state: (@) DOCUMENT means a writing, as defined in Evidence (a) the state or other issuing entity; Code section 250, and includes the original or a copy of (b) the license number and type; handwriting, typewriting, printing, photostats, photographs, (©) 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 or representation, including letters, words, pictures, sounds, or 2.4 Atthe time of the INCIDENT, did you have any other permit or license for the operation of a motor vehicle? If so, symbols, or combinations of them. state: (e) HEALTH CARE PROVIDER includes any PERSON referred to in Code of Civit Procedure section 667.7(e)(3). @ the state or other issuing entity; ® ADDRESS means the street address, including the city, (b) the license number and type; state, and zip code. © the date of issuance; and (d) all restrictions. Sec. 5. Interrogatories The following interrogatories have been approved by the Judicial 25 State: Council under Code of Civil Procedure section 2033.710: @ your present residence ADDRESS; (b) your residence ADDRESSES for the past five years; CONTENTS and 1.0 Identity of Persons Answering These Interrogatories (©) the dates you lived at each ADDRESS. 2.0 General Background Information—Individual 26 State: 3.0 General Background Information—Business Entity 4.0 Insurance fa) the name, ADDRESS, and telephone number of your present employer or place of self-employment; and 5.0 [Reserved] 6.0 Physical, 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- employment you have had from five years before the 8.0 Loss of Income or Earning Capacity INCIDENT until today. 9.0 Other Damages 10.0 Medical History Wy 27 State: 11.0 Other Claims and Previous Claims (@) the name and ADDRESS of each school or other 12.0 Investigation—General academic or vocational institution you have attended, 13.0 Investigation—Surveillance beginning with high school; 14.0 Statutory or Regulatory Violations (b) the dates you attended; 15.0 Denials and Special or Affirmative Defenses {c) the highest grade level you have completed; and 16.0 Defendant's Contentions Personal Injury {d) the degrees received. 17.0 Responses to Request for Admissions 18.0 [Reserved] 2.8 Have you ever been convicted of a felony? If so, for 19.0 [Reserved] each conviction state: 20.0 How the Incident Occurred - Motor Vehicle @ the city and state where you were convicted; 25.0 [Reserved] (b) the date of conviction; 30.0 [Reserved] (c) the offense; and 40.0 [Reserved] (@) the court and case number. 50.0 Contract 29 Can you speak English with ease? If not, what 60.0 [Reserved] language and dialect do you normally use? 70.0 Unlawful Detainer [See separate form DISC-003] 101.0 Economic Litigation [See separate form DISC-004] [MR 2.10 Can you read and write English with ease? If not, 200.0 Employment Law [See separate form DISC-002] Family what language and dialect do you normally use? Law [See separate form FL-145] DISC-001 [Rev. Jonuary 1, 2024] CEES]Essential FORM INTERROGATORIES—GENERAL Pago 2 of 8 ceb,com | {i)Forms: Griffin, Carrie DISC-001 2.11 At the time of the INCIDENT were you acting as an fj 34 Are you a joint venture? If so, state: agent or employee for any PERSON? If so, state: (@) 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. () the name and ADDRESS of each joint venture; and 2.12 At the time of the INCIDENT did you or any other qd) the ADDRESS of the principal place of business. person have any physical, emotional, or mental disability or O35 Are you an unincorporated association? If so, state: condition that may have contributed to the occurrence of the @ the current unincorporated association name; INCIDENT? If so, for each person state: (b) all other names used by the unincorporated association (a) the name, ADDRESS, and telephone number; during the past 10 years and the dates each was used; (b) the nature of the disability or condition; and and (c) the manner in which the disability or condition (c)_ the ADDRESS of the principal piace of business. contributed to the occurrence of the INCIDENT. CU 3.6 Have you done business under a fictitious name during 2.13 Within 24 hours before the INCIDENT did you or any the past 10 years? If so, for each fictitious name state: person involved in the INCIDENT use or take any of the (a) the name; following substances: alcoholic beverage, marijuana, or (b) the dates each was used; other drug or medication of any kind (prescription or not)? If (c) the state and county of each fictitious name filing; and so, for each person state: (d) the ADDRESS of the principal place of business. (a) the name, ADDRESS, and telephone number; (b) the nature or description of each substance; (J 3.7 Within the past five years has any public entity () the quantity of each substance used or taken; registered or licensed your business? If so, for each (@) the date and time of day when each substance was used license or registration: or taken; @ identify the license or registration; (e) the ADDRESS where each substance was used or (b) state the name of the public entity; and taken; (c)_ state the dates of issuance and expiration. a the name, ADDRESS, and telephone number of each 4.0 Insurance person who was present when each substance was used 4.1 At the time of the INCIDENT, was there in effect any or taken; and policy of insurance through which you were or might be (9) the name, ADDRESS, and telephone number of any insured in any manner (for example, primary, pro-rata, or HEALTH CARE PROVIDER who prescribed or furnished excess liability coverage or medical expense coverage) for the substance and the condition for which it was the damages, claims, or actions that have arisen out of the prescribed or furnished. INCIDENT? If so, for each policy state: 3.0 General Background Information—Business Entity @ the kind of coverage; (31 Are you a corporation? If so, state: (b) the name and ADDRESS of the insurance company; (a) the name stated in the current articles of incorporation; ©) the name, ADDRESS, and telephone number of each (b) all other names used by the corporation during the past named insured; 10 years and the dates each was used; qd) the policy number; © the date and place of incorporation; ©) the limits of coverage for each type of coverage con- (d) the ADDRESS of the principal place of business; and tained in the policy; () whether you are qualified to do business in California. 6 whether any reservation of rights or controversy or coverage dispute exists between you and the insurance Cy 32 Are you a partnership? If so, state: company; and @) the current partnership name; (b) all other names used by the partnership during the past (g) the name, ADDRESS, and telephone number of the custodian of the policy. 10 years and the dates each was used; 4.2 Are you self-insured under any statute for the damages, © whether you are a limited partnership and, if so, under claims, or actions that have arisen out of the INCIDENT? If the laws of what jurisdiction; so, specify the statute. {d) the name and ADDRESS of each general partner; and ) the ADDRESS of the principal place of business. 5.0 [Reserved] Ci 33 Are you a limited liability company? If so, state: 6.0 Physical, Mental, or Emotional Injuries @) the name stated in the current articles of organization; (b) all other names used by the company during the past 10 (2) 6.1 Do you attribute any physical, mental, or emotional years and the date each was used; injuries to the INCIDENT? (if your answer is “no,” do not answer interrogatories 6.2 through 6.7). (c) the date and place of filing of the articles of organization; @) the ADDRESS of the principal place of business; and (2) 6.2. Identify each injury you attribute to the INCIDENT and ) whether you are qualified to do business in California. the area of your body affected. DISC-001 (Rev, January 1, 2024] Page 3 of8 FORM INTERROGATORIES—GENERAL MEICEB| Essential Griffin, Carrie ceb.com | {Farms DISC-001 (21 6.3 Do you still have any complaints that you attribute to (©) state the amount of damage you are claiming for each the INCIDENT? If so, for each complaint state: item of property and how the amount was calculated; and @ a description; (a) _ if the property was sold, state the name, ADDRESS, and (b) whether the complaint is subsiding, remaining the same, telephone number of the seller, the date of sale, and the or becoming worse; and sale price. © the frequency and duration. 7.2 Has a written estimate or evaluation been made for any Les Did you receive any consultation or examination item of property referred to in your answer to the preceding (except from expert witnesses covered by Code of Civil interrogatory? If so, for each estimate or evaluation state: Procedure sections 2034.210-2034.310) or treatment from a @) the name, ADDRESS, and telephone number of the HEALTH CARE PROVIDER for any injury you attribute to PERSON who prepared it and the date prepared; the INCIDENT? If so, for each HEALTH CARE PROVIDER ) the name, ADDRESS, and telephone number of each state: PERSON who has a copy of it; and (@) the name, ADDRESS, and telephone number; {c) the amount of damage stated. (b) the type of consultation, examination, or treatment 7.3 Has any item of property referred to in your answer to provided; interrogatory 7.1 been repaired? If so, for each item state: © the dates you received consultation, examination, or treatment; and @) the date repaired; (b) a description of the repair; @) the charges to date. ©) the repair cost; 6.5 Have you taken any medication, prescribed or not, as a (a) the name, ADDRESS, and telephone number of the result of injuries that you attribute to the INCIDENT? If so, PERSON who repaired it; for each medication state: ) the name, ADDRESS, and telephone number of the @) the name; PERSON who paid for the repair. (b) the PERSON who prescribed or furnished it; 8.0 Loss of Income or Earning Capacity © the date it was prescribed or furnished; (2) 8.1 Do you attribute any loss of income or earning capacity @) the dates you began and stopped taking it; and to the INCIDENT? (if your answer is "no," do not answer @) the cost to date, interrogatories 8.2 through 8,8). Cy 66 Are there any other medical services necessitated by the Cj a2 State: injuries that you attribute to the INCIDENT that were not previously listed (for example, ambulance, nursing, (a) the nature of your work; prosthetics)? If so, for each service state: (b) your job title at the time of the INCIDENT; and (a) the nature; ) the date your employment began, (b) the date; Ci a3 State the last date before the INCIDENT that you © the cost; and worked for compensation. @ the name, ADDRESS, and telephone number (J 8.4 State your monthly income at the time of the INCIDENT of each provider. and how the amount was calculated. 67 Has any HEALTH CARE PROVIDER advised that you may require future or additional treatment for any injuries (C2) 8.5 State the date you returned to work at‘each place of that you attribute to the INCIDENT? If so, for each injury employment following the INCIDENT. state: (J 8.6 State the dates you did not work and for which you lost (@) the name and ADDRESS of each HEALTH CARE income as a result of the INCIDENT. PROVIDER; (b) the complaints for which the treatment was advised; and (CQ 8.7 State the total income you have lost to date as a result ©) the nature, duration, and estimated cost of the of the INCIDENT and how the amount was calculated. treatment. C) 8.8 Will you lose income in the future as a result of the 7.0 Property Damage INCIDENT? If so, state: 7.1 Do you attribute any loss of or damage to a vehicle or (@)_ the facts upon which you base this contention; other property to the INCIDENT? If so, for each item of (b) an estimate of the amount; property: (c) an estimate of how long you will be unable to work; and (a) describe the property; (@)_ how the claim for future income is calculated. (b) describe the nature and location of the damage to the Property; BiSC-004 (Rev. January 1, 2024] Page 4of8 FORM INTERROGATORIES—GENERAL WECEB] Essential ceb.com| Griffin, Carrie DISC-001 9.0 Other Damages ©) the court, names of the parties, and case number of any (223 9.1 Are there any other damages that you attribute to the action filed; INCIDENT? If so, for each item of damage state: @ the name, ADDRESS, and telephone number of any (a) the nature; attorney representing you; (b) the date it occurred; @) whether the claim or action has been resolved or is (c) the amount; and pending; and {d) the name, ADDRESS, and telephone number of each 0 a description of the injury. PERSON to whom an obligation was incurred. 11.2 In the past 10 years have you made a written claim or C) 9.2 Do any DOCUMENTS support the existence or amount demand for workers' compensation benefits? If so, for each of any item of damages claimed in interrogatory 9.1? If so, claim or demand state: describe each document and state the name, ADDRESS, (@) the date, time, and place of the INCIDENT giving rise to and telephone number of the PERSON who has each the claim; DOCUMENT. () the name, ADDRESS, and telephone number of your employer at the time of the injury; 10.0 Medical History {J 10.1 At any time before the INCIDENT did you have com- © the name, ADDRESS, and telephone number of the workers’ compensation insurer and the claim number, plaints or injuries that involved the same part of your body claimed to have been injured in the INCIDENT? If so, for @ the period of time during which you received workers' compensation benefits; each state: (a) a description of the complaint or injury; ) a description of the injury; (b) the dates it began and ended; and ® the name, ADDRESS, and telephone number of any HEALTH CARE PROVIDER who provided services; and (c) the name, ADDRESS, and telephone number of each HEALTH CARE PROVIDER whom you consulted or (g) the case number at the Workers' Compensation Appeals Board. who examined or treated you. 12.0 Investigation—General a 10.2 List all physical, mental, and emotional disabilities you 12.1 State the name, ADDRESS, and telephone number of had immediately before the INCIDENT. (You may omit each individual: mental or emotional disabilities unless you attribute any mental or emotional injury to the INCIDENT.) @) who witnessed the INCIDENT or the events occurring immediately before or after the INCIDENT; CJ 10.3 At any time after the INCIDENT, did you sustain (b) who made any statement at the scene of the INCIDENT; injuries of the kind for which you are now claiming (©) who heard any statements made about the INCIDENT damages? If so, for each incident giving rise to an injury by any individual at the scene; and state: @) who YOU OR ANYONE ACTING ON YOUR BEHALF {a) the date and the place it occurred; claim has knowledge of the INCIDENT (except for {b) the name, ADDRESS, and telephone number of any expert witnesses covered by Code of Civil Procedure other PERSON involved; section 2034). (c) the nature of any injuries you sustained; 12.2 Have YOU OR ANYONE ACTING ON YOUR {d) the name, ADDRESS, and telephone number of each BEHALF interviewed any individual concerning the HEALTH CARE PROVIDER who you consulted or who INCIDENT? If so, for each individual state: examined or treated you; and (e) the nature of the treatment and its duration. f@) the name, ADDRESS, and telephone number of the individual interviewed; 11.0 Other Claims and Previous Claims (by the date of the interview; and [-¥ 11.1 Except for this action, in the past 10 years have you (©) the name, ADDRESS, and telephone number of the filed an action or made a written claim or demand for PERSON who conducted the interview. compensation for your personal injuries? If so, for each action, claim, or demand state: 12.3 Have YOU OR ANYONE ACTING ON YOUR BEHALF obtained a written or recorded statement from any (a) the date, time, and place and location (closest street individual concerning the INCIDENT? If so, for each ADDRESS or intersection) of the INCIDENT giving rise statement state: to the action, claim, or demand; (b) the name, ADDRESS, and telephone number of each @ the name, ADDRESS, and telephone number of the PERSON against whom the claim or demand was made individual from whom the statement was obtained; or the action filed; {b) the name, ADDRESS, and telephone number of the individual who obtained the statement; {c) the date the statement was obtained; and (d) the name, ADDRESS, and telephone number of each PERSON who has the original statement or a copy. DISC-001 fRey, Jenuary 1, 2024] FORM INTERROGATORIES—GENERAL Page 50f8 EECEB) Essential ceb.com | fa}Forms- Griffin, Carrie DISC-001 () 12.4Do YOU OR ANYONE ACTING ON YOUR BEHALF 43.2 Has a written report been prepared on the know of any photographs, films, or videotapes depicting any surveillance? lf so, for each written report state: place, object, or individual concerning the INCIDENT or @ the title; plaintiff's injuries? !f so, state: (b) the date; (a) the number of photographs or feet of film or videotape; © the name, ADDRESS, and telephone number of the (b)_ the places, objects, or persons photographed, filmed, or individual who prepared the report; and videotaped; (d) the name, ADDRESS, and telephone number of each () the date the photographs, films, or videotapes were PERSON who has the original or a copy. taken; 14.0 Statutory or Regulatory Violations (@) the name, ADDRESS, and telephone number of the 14.1 Do YOU OR ANYONE ACTING ON YOUR BEHALF individual taking the photographs, films, or videotapes; contend that any PERSON involved in the INCIDENT and violated any statute, ordinance, or regulation and that the ©) the name, ADDRESS, and telephone number of each violation was a legal (proximate) cause of the INCIDENT? If PERSON who has the original or a copy of the so, identify the name, ADDRESS, and telephone number of photographs, films, or videotapes. each PERSON and the statute, ordinance, or regulation that was violated. 12.5Do YOU OR ANYONE ACTING ON YOUR BEHALF 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- 2034.30) conceming the INCIDENT? If so, for each item @) the name, ADDRESS, and telephone number of the PERSON; state: (a) the type (.e., diagram, reproduction, or model); (b) the statute, ordinance, or regulation allegedly violated; (b) the subject matter; and © whether the PERSON entered a plea in response to the eltation or charge and, if so, the plea entered; and (c) the name, ADDRESS, and telephone number of each PERSON who has it. @ 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 15.0 Denials and Special or Affirmative Defenses. INCIDENT? If so, state: (2) 15.1 Identify each denial of a material allegation and each @ 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 special (b) the date and type of report made; or affirmative defense; () the name, ADDRESS, and telephone number of the () state the names, ADDRESSES, and telephone numbers PERSON for whom the report was made; and of all PERSONS who have knowledge of those facts; and (d) the name, ADDRESS, and telephone number of each {c) identify all DOCUMENTS and other tangible things that PERSON who has the original or a copy of the report. support your denial or special or affirmative defense, and state the name, ADDRESS, and telephone number of 12.7 Have YOU OR ANYONE ACTING ON YOUR the PERSON who has each DOCUMENT. BEHALF inspected the scene of the INCIDENT? If so, for 16.0 Defendant's Contentions—Personal Injury each inspection state: (a) the name, ADDRESS, and telephone number of the [J] 16.1 Do you contend that any PERSON, other than you or plaintiff, contributed to the occurrence of the INCIDENT or individual making the inspection (except for expert the injuries or damages claimed by plaintiff? If so, for each witnesses covered by Code of Civil Procedure PERSON: sections 2034,210-2034.310); and (b) the date of the inspection. (@) state the name, ADDRESS, and telephone number of the PERSON; 13.0 Investigation-Surveillance () state all facts upon which you base your contention; 13.1 Have YOU OR ANYONE ACTING ON YOUR BEHALF (c) state the names, ADDRESSES, and telephone numbers. conducted surveillance of any individual involved in the of all PERSONS who have knowledge of the facts; and INCIDENT or any party to this action? If so, for each sur- @ identify all DOCUMENTS and other tangible things that veillance state: support your contention and state the name, ADDRESS, @) the name, ADDRESS, and telephone number of the and telephone number of the PERSON who has each individual or party; DOCUMENT or thing. (b) the time, date, and place of the surveillance; 16.2 Do you contend that plaintiff was not injured in the © the name, ADDRESS, and telephone number of the INCIDENT? If so: individuat who conducted the surveillance; and (a) state all facts upon which you base your contention; {d) the name, ADDRESS, and telephone number of each (b) state the names, ADDRESSES, and telephone numbers PERSON who has the original or a copy of any of all PERSONS who have knowledge of the facts; and surveillance photograph, film, or videotape. () identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON whe has each DOCUMENT or thing. DISC-001 [Rev. January4, 2024} FORM INTERROGATORIES—GENERAL Page Gof 8 ECEB) Essential Griffin, Carrie ceb.com | fs]Forms: DISC-001 (2 18.300 you contend that the injuries or the extent of the (QJ 16.8 De you contend that any of the costs of repairing the injuries claimed by plaintiff as disclosed in discovery property damage claimed by plaintiff in discovery proceedings thus far in this case were not caused by the proceedings thus far in this case were unreasonable? If so: INCIDENT? If so, for each injury: {a) identify each cost item; (@) identify it; (b) state all facts upon which you base your contention; ) state all facts upon which you base your contention; () state the names, ADDRESSES, and telephone numbers (©) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and of all PERSONS who have knowledge of the facts; and (@) identify all DOCUMENTS and other tangible things that @) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each and telephone number of the PERSON who has each DOCUMENT or thing. DOCUMENT or thing. [2] 16.9 Do YOU OR ANYONE ACTI