Exhibit,Appendix: PATRICK KELLY VS. SHANE CLARIDGE KELLEY, AS EXECUTOR OF THE THOMAS F. et al

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                                ELECTRONICALLY

PATRICK KELLY FILED
3790 El Camino Real, #1009 Superior Court of Catifornia,
Palo Alto, CA 94306 County of San Francisco
(415) 769-9524 10/02/2017
mailforpatkelly@gmail.com Clerk of the Court

BY:JUDITH NUNEZ
Deputy Clerk

Plaintiff, In Pro Per

SUPERIOR COURT FOR THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO:

(Unlimited Jurisdiction)

PATRICK KELLY, Case No.: CGC-13-535823

Plaintiff. EXHIBITS G ~ J IN SUPPORT OF
MOTION FOR LEAVE TO FILE
VERIFIED SECOND AMENDED
COMPLAINT

vs.

SHANE CLARIDGE KELLEY, AS EXECUTOR

etal, Date: October 11, 2017

Location: Dept. 302

Time: 9:00 a.m.

Judge: Hon. Harold E. Kahn
Action Filed: December 2, 2013
Trial Date: October 23, 2017

Defendants.

EXHIBITS G- J
Plaintiff Patrick Kelly hereby declares under penalty of perjury under the laws of the State

of California that Exhibits G-J attached hereto are true and correct copies of their originals,

DATED: September 3D .2017

EXHIBITS G-J IN SUPPORT OF MOTION FOR LEAVE TO FILE VERIFIED SECOND AMENDED COMPLAINT
CGC13-535823EXHIBIT “G”
COURT ORDER CONFIRMING THE BREACH OF CONTRACT COA
DID NOT ACCRUE UNTIL THE ESTATE REJECTED PLAINTIFF’S CREDITOR CLAIM

PLAINTIFF EXHIBIT PAGE - 137ME

SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO

Document Scanning Lead Sheet
Mar-23-2016 10:19 am

Case Number: CGC-13-535823
Filing Date: Mar-23-2016 10:18
Filed by: ROSIE NOGUERA
Image: 05325220
ORDER

PATRICK KELLY VS. JACK EUGENE TEETERS, AS EXECUTOR OF THE
THOMAS F. et al

001005325220

Instructions:
Please place this sheet on top of the document to be scanned.

PLAINTIFF EXHIBIT PAGE - 138woe UN DA HW FF BW NY

o NV & oS

14

PATRICK KELLY : Superior Court of California
1225 Vienna Dr., SPC 973 Sana
Sunnyvale, CA 94089
(t 5) 769-9524 : MAR 23 2016
mailforpatkelly@gmail.com , CLERK OF THE COURT
Plaintiff In Pro Per of jeputy Clerk
SUPERIOR COURT FOR THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
(Unlimited Jurisdiction)
PATRICK KELLY, Case No.: CGC 13-535823
Plaintiff ; ORDER OVERRULING DEFENDANTS’
: DEMURRER TO THE FIRST AMENDED
vs. COMPLAINT
Res. No. 10270323-10
een ee Wiehe as Executor, of the Hearing Date: March 23, 2016
7 ‘ Judge: Hon Harold E. Kahn
Does 1-25 Inclusive,
Defendants.

Defendants’ demurrer to the First Amended Complaint came on for hearing on March 23,
2016, at 9:30 a.m. in'Department 302 of the above entitled Court, Hon Harold E. Kahn, presiding.
Geoffrey Rotwein appeared for the defendants and plaintiff Patrick Kelly appeared in pro per.

In consideration of all the evidence set forth in the papers submitted and oral arguments
presented by the parties, the Court makes the following determination:

Defendant's demurrer is overruled. The summary adjudication order in the prior case was
not based on failure of a condition precedent. That order is entirely consistent with and are governed
by the court of appeal's decision in this case which states, in footnote 12 on page 20, that "this cause
of action did not accrue until White died and appellant's creditor's claim was rejected by the estate."
Defendant's res judicata argument is thus without merit and none of plaintiff's claims are time

barred as a matter of law. They all accrued when the creditor's claim was denied.

-1-

ORDER OVERRULLING DEFENDANTS’ DEMURRER TO FIRST AMENDED COMPLAINT - CGC13-535823
PLAINTIFF EXHIBIT PAGE -

139IDATED: Marchi? _, 2016

-2-

oy

HON. HAROLD.E. KAHN
JUDGE OF THE SUPERIOR COURT

ORDER OVERRULLING DEFENDANTS’ DEMURRER TO FIRST AMENDED COMPLAINT - CGC13-535823

PLAINTIFF EXHIBIT PAGE -

140EXHIBIT “H”
DISCOVERY PROPOUNDED BY DEFENDANT UPON PLAINTIFF IN PREVIOUS CASE

PLAINTIFF EXHIBIT PAGE - 141DISC -001

TATORNEY GA PARTY VATROUT ATTORNEY (Naps, Sine Bor name’, ane arma

GEOFFREY ROTWEEN (SBN 58176)
40) Montgomery Street, Second Floor
San Francisco, CA 94104

FeUESHONE NO, 4} 5-397-41R860

PAX WO, (Opto) 415-397-0862

Fth ADORESS (Optoma

ATronKey FOR one Defendant Thomas White

SUPERIOW GOURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO

‘SHORT TITLE OF GASE:
PATRICK KELLY v. THOMAS WHITE

FORM INTERROGATORIES—-GENERAL

Asking Party: Defendant Thomas White

Answering Party: Plaintiff Patrick Kelly

SetNo.: One

‘CASE NUMBER

CPF-09-494198

Sec. 1. Instructions to All Parties

(2) interrogatories are written questions prepared by @ parly
to an action that are sent to any other perty in the action to be
answered under oath, The interrogatories below are form
interrogatories appraved for use in civil cases.

(b} For lime limitations, requirements for service on other
patties, and other details, see Code of Civil Procecure
sections 2030.0 10-2030 410 and the cases construing those
sections,

{c}_ These form interrogalories do not change existing faw
relating to interragaiories nor do they affect am answering
party's night to assert any privilege oF make any objection.

See. 2, Instructions to the Asking Party

(a) These interrogatories are designed for optional use by
pattice in unlimited civil cacse whore the amount demanded
exceeds $25,000. Separate interrogatories, Form
Intorrogatories—L imited Civil Cases (Economic Litigation)
(form DISC-004}, which have no subparts, are designed for
use in limited divi cases where the amount demanded ie
$25,000 or less; however, those inlerrogaicries may also be
used in Unlimited civil cases,

(b) Check the box next to each interragatory that you want
the answering party to answer. Use care in choosing ese
inlerrogaiones thal are applicable to the case.

{c) You may insett your own definition of INCIDENT in
Section, but only where the action arises froma course of
conduct of a series of events occurring over a period of time.
id). The interrogatories in section 16.0, Defendant's
Cententiens-Personal Injury, should not be used until the
defendant has nad a resonable opportunity te conauct an
Investigation or discovery of plainti’s injuries and damages.
(©) Additional interrogatories may be attached

Sei-3. lastructions to the Answering Party
(2). An answer or ether appropriate response must be
given to each Interrogalory checked by the asking party

(b) Asa general rule, within 30 days after you ere served

ih these intetrogatories, you must serve your responses on
the esking parly and serve copies of your responses on all
other parlies lo the action whe have appeared. See Code of
Civil Procedure sections 2030,260-2030.270 for details,

{s). Each enewer must be:as complete and straightforward
a8 the information teasenably available to you, inckiding the
information possessed by your altorneys or agents, permits. If
ani interrogatory cannot be answered-completely, answer it to
the extent possibis,
(@)_ tf youdo not have enough personal knawledye to fully
answer an interrogetory, say so, but make 4 reasonable and
‘Sood faith) offort to gol the Information by asking other persons
of organizations, unless the information is equally avallable to
the asking party,
(e) Whenever an interrogatory may be answered by
referring to 4 document, the document may be attached as an
‘exhibit fo the response and refered to in the response. If the
document has more than one page, refer to the paye and
section where the snswer to the Inlerrogatary can be found,
() Whenever an address and telephone number tor the
‘same person are requested in more than one interrogatary,
you are required to furnish ther in answering only the first
inlerragatory asking for that information:
(9) f you are asserling a privilege or making an objection to
an interrogatory, you must specifically assert the privilege'or
state the objection in your written response
ih) Your anewors to these interrogatories muathe verified,
dated, and signed, You may wish te Use the following form at
the end of your answers:

I dectare: under poneliy of perjury under the lews of the
State of California thet the foreaving answers are true and
correct.

(ATS) (SIGNATIRS)

Sec.4. Definitions

Words in BOLDFACE CAPITALS in these interrogatories

ate dofined as follows:

(@) (Check ane of the following):

[J (1) INCIWENT includes the circumstances and
vents surrounding the alleged accident, injury, oF
other occurrence or breach of contract giving rise te
this action or proceeding.

Page tot
Pee er cwere FORM INTERROGATORIES—GENERAL wicomoeeeoen ne
SISC 901 FRev donusry 1, 2508) war ccontfh eae

PLAINTIFF EXHIBIT PAGE - 142[Z}-@) NemENT means {iron you defetion here a

Alleged oral contract on October 12,
2005.

tb) YOU OR ANYONE ACTING ON YOUR BEHALF
includes you, your agents,

companies, their agents, their employees, your attorneys, yout
accountants, your Investigators, and anyone else acting ot
your bahelf:

(0) PERSON includes 9 natural person, firm, asscciation,
‘erganization, partnership, business, trust, limited liability
company. comsoration. or public entity

(2) DOCUMENT means a writing, as defined in Evidence
includes: ¥

‘or representation, 1 leflers, words, pictures, sounds, oF
symbals, or combinations ot ‘them:
{s) HEALTH CARE PROVIDER i: inchudes any PERSON:
referred to in Code of Civil Procedure section $67. 7(e}(3),

{f) ADDRESS means the street address, including the city,

Sse.5, interrogatories

The faftowing inter jas have been approved by the

sludicial Courcii under Code of Civil Procedure section 2033.710:

CONTENTS:

i o Cen of Persons Answering These
General Background Infor

‘oparty Damage
bone eae ‘of Earning Capacity
100 Weaeat stay,
AER her Giatne and Previous Claiins:
0 Investigation—General

ue Investigation—Surveiliance

14.0 Statuary or Regulatory Violations:

48.0 Denials anc! Special or Affirmative Defenses
16.0 Defendant's Contentions Personal i

17.0 Renponsos to Request for Admissions

: served!

sserved!
29 How the Incident Oseurred—Motor Vehicle

form
Family Law {See separate form FL:145)

DISC-001
1.0 Identity of Persons Answering These interrogatories
[¥] 441 state: the name,

responses to these.
interrogatories. (Do not identify anyone who simply typed or
reproduced the responses )

2.0 General Background Information—individual

FZ] a1 state:
(8) your name;
amie You have used ip the past aie
aa 3 You used each name.

2.2 State the date and place of your birth,

[Z] 23.41 the une of the INCIDENT, did you have a driver's
jicense? If so stale:
ia fe the state or other issuing entity;

[Z] 24 Attho time of he INCIDENT, did you have ony olher
Deri of teanse for the operation of rotor Vehicle? i So,

oe the state of cther ‘suing erty:
{) the ficense number and typo;
(c} the date of issuance: and

(d} all restrictions.

1) 25 sate:
{a} your prasent fesidence ADDRESS;
(6) four fesorce ADDRESSES for the pos tve yoats and
{¢) the dates you lived at each ADDRESS.

[7] 26 state.
{a} the neme, ADORESS, and jelephone number of your
present employer or place of selfemplayment; and
(6) the name, ADDRESS, dates of emple
‘and nature of work for each owe ~

FN 2 Site

(©) the dates you aitended,
) the hrgbest rade level au nove completed and
“(d) the degrees receive:

Mee 28 Have you ever been convicted of 2 felony? ifs, tor

(2) thes and stale where convicted:
et Bech es we Poet

(c) the'affense; and

(@) the court and case number.

[1] 2% Gan you speak English with ease? if not, what
2, aa you aeah Eval i use?

(71 210.0an youn nd ote nah wth oe, vat
language and dialert do you normally use’

CEERI Gana VI

~‘.
Wiiiccttianicsssersininammen

FORM INTERROGATORIES—GENERAL

Page zt

PLAINTIFF EXHIBIT PAGE - 143DRED Rev iavey 1

[7] 2:1 Atths time of the INCIDENT were you acting as an
agent or employes for any PERSON? If so, slate:
(=) the name, ADDRESS, and telephone number of that
PERSON: and
(bp) adescription of your duties,

2,12 At the time of the INCIDENT did you or any of

person have any physical, emotional, or mental disability or

condition thal may heve contributed to the occurrence’ of the

INCIDENT? IF s0, for each parson state;

(8) the name, ADDRESS, and telephone number;

(2) the nature of the disability or conditian, and

{e) the manner in which the disability oF
contributed to the occurrence of the INCIDENT.

condition

2.49 Within 24 hours before the INCIDENT did you of any

person invalved in the INCIDENT use of lake any ef the

following substances: alcholic beverage, marijuana, or

otier drug or medication of any kind (prescription or not}? If

$0, for each person state

(a) the name, ADDRESS, and telephone number;

(b} the nature or description of each substance;

(©) the quantity of each substance used or takent

(d) the date and Gime of day when exch substance was used
‘or taken;

(@) the ADDRESS where each substance was sad or
taken:

() the name, ADDRESS, and telephone number of sack

person who was present when each substance was used

of takasty; and

the name, ADDRESS, and telephone number of any

HEALTH CARE PROVIDER who prescribed or furnished

the substance and the condilion for which it was

prescribed or furnished

{g

a

General Background Information—Business Entity

3.4. Are you a corporation? If so, state:

(2) the name stated in the current articles of incorporation;

(b) all other names used by the corporation during the past
10 years and the dates each was used;

{o} the date and place of incorporation;

(d} the ADDRESS of the principal place of business; and

{®) Whether you are qualified to. do business in California,

2.2) Are you a partnership? I! so, state:

(a) the current partnership name;

(p) all other names used by the parinership during the past
10 years and the dales each was used;

(€) whether you are a limited partnership and, if 60, under
the laws of what jurisdiction;

(d) the name and ADDRESS of each general partner, and

(@) the ADDRESS of the principal plece of business,

32 Are you a limited liability company? If so, state:

{a} the name stated in the current articles of organization;

(b} all other names used by the company during the past 10
yearsand the date each was used

(C] the date and piace of fling of the articles of organization

(el) the ADDRESS of the principal place of husinese; and

{e) whether you are qualified to de business in Cebfornia

oO

DISC-001
34 Ate you a joint venture’ If so, stale:
(a) the current join! venture name;
{b) allothernames used by the joint venture during the
past 10 years and the dates each was usect;
(6) the name and ADDRESS of each jant venturer; and
(0) the ADDRESS of the principal place of busine:

35 Are you an unincorparated association?

liso, s

(a) the current unineorparated association name:

(b) all other names used by the unincorporated association
during the past 10 years and the dates each was used
and

(o) the ADDRESS of the principal place of business.

3.8 Have you done business under a fictitious name during
the past 10 years? If so, for each fictitious name state

(a) the name:

(b) the dates each was used:

{6} the state and county of each fictilious name filing; and
(a) the ADDRESS of the principal place of business.

2,7 Within the past five years has any public entity regia~
tered or licensed your business? If so, for each licehse of
registration:

{a) identify the license or registration,

(b) state the name oF the public ently, and

(c) slate the dales of issuance and expiration.

40 insurance

oO

Cl

4.4 AU(he time ofthe INCIDENT, was there in elfect any

policy of insurance through which you were ot might be

insured in any manner (for example, primary, pro-rata, or
excess liability coverage or medical expense coverage) for
the damages, claims, or actions that nave arisery aut of the

INCIDENT? if s0, for each policy state:

(a) the kind of coverage;

(b) the name and ADDRESS of the insurance company,

{o} the nate, ADDRESS, and telephone number of each
named insured;

(@) the policy number;

{e) the limits of coverage for each type of coverage con-
tained In the policy;

{1} whether any reservation af rights or controversy. of
coverage dispule exists belween you and the insurance
companyyand

{a) the name, ADDRESS, and telephone numberof the
custodian of the potiey.

42 Are you self-insured under any statute for the damages,
claims. 0” actions that have arisen oul of the INCIDENT? If
84, specify the statute,

8.0 [Reserved

6.0

oO

Oo

Physical, Mental, or Emotional Injuries

6.1 Do you attribute any physical, mental, or emotional
injunes to tne INCIDENT? (if your answer is “no,” do not
answer interrogatories 6.2 through 6.7).

8.2 Identify each injury you atiribute lo the INCIDENT and
the area of your body affected.

FORM INTERROGATORIES—GENERAL

Papa d of

PLAINTIFF EXHIBIT PAGE - 144DISC-4001
(6) Slate the amount of damiage you ane claiming for each
itor of peoperty and how the amount was calculated: and
{a} if the property was sold, state the name, ADDRESS, anit
telephone number of the setier, the date of sale; and:the
‘sale price.

[63 Bo you sti fave any that yeu altibite to
‘he INCIDENT? if 30, toy exehconptat sale
® a description:
{b) whether the complaint is subsiding, remaining the name,
oF becoming worse: and
_ ho fhe ehepieney anc Clete,
[C]a¢ bid. you recene any consitation or
(e from.

exenination
‘ee wwraten [1] 22 Has o written estimete’cr evaluation bean made for ary

ate vwhnessers orderly talered ‘aoswer coding
hea Se ae ak ev g10) erat poss iiuregeg? Fan te eam eae or vahelor cai
HEALTH CARE PROVI any johuty. you atinbute :
the INCIDENT? jf sa, for each HEALTH CARE PROVIDER W aodcomeicdim nee
state: (0) the namie, ADDRESS, and telephone number af each
(a) the name, ADDRESS, and telephorie number, BEREON who Bae a copy of ond
(b) the type of consultation, examination, or * peatment (6) the amount of damage stuled,
16) the dates jou received consultation, examination, ar Ove

a retorted: te ih your answer to
(@ trechargie to dana: ‘been repaid? iso, foreach item stae:

Nee! o ihe dtd rene

{b). a description of the repair;
BB Ma fanen any medication, prescribed ot net,
Tg ie se oy ice abet akan io oe reek Ab J i slat
Seem BON ote renaredil lephone number
6 Ia DES on sais drmserioedur Gsnninet te {@) the name, ADDRESS, ‘ond telephone numiber of the
E me dale tet petit amit PERSON who paid lar the repair
began and stoppad t aod
(a) the nos dete 8.0 Loss of Income or Earning Capacity

[2] 8:1. Do you attribute any oss of income: or eating capacity
Ces Ave thens any other medica) services necessitated by to the INCIDENT? (If your anawer is. “pu,” do not answer
pea tga ys ane fe ENT Bae

interngatorien 8.2 through B.8).

patel)? 50, ts ouct servi lal : ”
82 State:

a Poa @ tha nature of your wat;

te) Secost wid te eee

(4) the nerae, ADDRESS, arid telephone rastition fe “pour orapfoyenent hegers

teach provider, [¥) 23 Siblp dee: inet foe balorw the RROENT hat yw

worked for compéncation:

[1 6.7 Hes ony HEALTH CARE PROVIDER advised that you

may require future or scitional treatment for any inher W184 ate monthly ineorne at the time of the N
that yor antl 1 the INCIDENT? W 90s for each Pyery ere we od —,

ha hhow the amount was eaioul
si

(a) the name and ADDRESS of each HEALTH CARE [¥] 95 State the date you rmlumed to work at each place af
Se PROVIDER; ‘emplayrnant following ther INCIDENT, 7

{0}: the complainte for which the treatment was advised, and
{o) the nature, duration. and estimated cost of the.

(7) 65 state the dates you did not work and for which you test

income as a tesuit of he INCIDENT.

7.0 Property Damage
Cyr Be you ati my ts uf or damage om vat ot
other property to the INCIDENT? if so. for each iter of

(0) dezertbe the propaty;
ei tessitia Fie Nein Ha logation of the damage to the

[71-87 state the tots income you have Jost to date 38 a result

of the INCIDENT and haw the amount was caiculated :

[2] 88. Will you tose inecinne in the Fulune sas: result of ie

INCIDENT? if so, state’
(a) the facts upon which you base this ebrtention;
{() an estimate of the arnount:
‘{c) an estimate of how long you will be unable to work; and
(a) how tha claim for tuharo income [s caleuiaied.

CRETE Few decors 1, 2008)

FORM INTERROGATORIES—-GENERAL, Page cart

PLAINTIFF EXHIBIT PAGE - 1459.0 Other Damages

9.4 Aro there any other damages that you attribute to the

INCWENT? if so, for each item of damage slale

(a) the nature;

(b) the date it occurred;

(©) the amount; and

(d) thename, ADDRESS, and telephone number of each
PERSON to whom an obligation was incurred.

$.2 Do any DOCUMENTS support the exisience of amount
of any item of damages: ciaimed in interrogatory 9.47 If so.
describe each document and state the neme, ADDRESS,
and telephone number of the PERSON who has each
DOCUNENT

10.0 Medical History

[7] 101 Atany ime before the INCIDENT did you have com.
plaints or injuries thal invoived the same part of your body
claimed to have been injured in the INCIDENT? If so, for
cach stale

(@) adescnption of the complaint of injury;

(6) the dales it began and ended, and

({c) the name, ADDRESS, ard telephone number of each
HEALTH CARE PROVIDER whom you consulted ar
viho examined or treated you,

[7] 10.2. List-ait physical, mental, and emotional disabities you
had immediately before the INCIDENT. (You may omit
mental or emotional disabilities uniess you attrioute any
mental or emotional injury (@ the INCIDENT.)

[7] 103. At any time attor the INCIDENT, did you sustain
Inuios of the kind for which you are now claimina
damages? If so, for each incident giving ri8e to an injury
state:

(a) the date and the place if occurred;

(b) the name, ADDRESS, and telephone number of any
other PERSON involved;

{e) the nature of eny injuries you sustained

(@) the name, ADDRESS, and telephone number of each
HEALTH CARE PROVIDER who you consulted or whe
‘examined of treated you: and

(8) the nature of the treatment and its duration

44.0 Other Claims and Previous Claims

[7 11.4 Except tor his action, in the past 10 years have you
fied an action cr made a written claim or demand for
compensation for your personal injuries? If so, for each
action, damm, ar demand state
(a) the date, lime, and place and location (clesest street
ADDRESS oF iniersection) of the INCIDENT giving rise
to the ection, claim; or demand,

(b} the name, ADDRESS, ond telephone number of each
PERSON against whom the claim or demand wes made
‘or the action filed:

DISC-001

(©) the court, names of the patties, and case number of any
action filed;

(8) the name, ADDRESS, and telephone number of any
attomey representing you;

() whether the claim or action has been resolved or is
pending; and

() adescription of the injury.

[71 11.2 tn the past 10 years have you madé.a witlen claim or

demand for workers’ compensation benefits? If so, for each

dlaim or demand state:

(a) the'date, time, and place of the INCIDENT giving tee to
the claim;

(0) the name, ADDRESS, ard telephone number of your
employer at the time of the injury;

(e). the name, ADDRESS, and telephone number of the
workers’ compensation insurer and the claim number;

(4) the period of tme: during which. you received workers’
compensation benefits;

(e) a deseription of the injury,

f) the name, ADDRESS, and !elephone number of any
HEALTH CARE PROVIDER who provided services; and

(g) the case number al the Workers" Compensation Appeals
Board.

12.0 Investigation—General

12.4 State the name, ADDRESS, ond telephone number of

each individual:

(a) who witnessed the INCIDENT or the events occurting
immediately before or afler the INCIDENT;

(b) who made any statement at the scone of the INCIDENT:

(c) who heard any staternents made about the INCIDENT by
any individual at the scene; and

(d) who YOU OR ANYONE ACTING ON YOUR BEHALF
claim has knowledge of the INCIDENT (except for
expert. witnesses covered by Code of Civil Procedure
section 2024).

122 Have YOU OR ANYONE ACTING ON YOUR

BEHALF interviowed -eny individual concerning the

INCIDENT? If so, for each individual state:

(a) the name, ADDRESS, and telephone number of the
individual interviewed

(h) the date of the interview; and

{s) the name, ADDRESS, and telephone number of the
PERSON who coneiticted the interview

123 Have YOU OR ANYONE ACTING ON YOUR

SEHALF obtained a written or recorded statement from any

individual concerning the INCIDENT? if a0, for Sach

statement state.

{a} the name, ADDRESS, and telephone nuinber of the
Individual from whom the statement was obtained;

tb) 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 stalement or 9 copy.

BSED RT Tancaiy Oo

FORM INTERROGAT ORIES—GENERAL.

Page Soft

PLAINTIFF EXHIBIT PAGE - 146[24 Ge YOU.OR ANYONE ACTING GN YOUR BEHALF
know of any photographs, films, or videotapes any
, OF individual concerning the INCIDENT or

Place, object,
plaintiff's injunes? (50, stale:

{a) Ihe number of phatographs or feet of fim or videotape;

(b) the places, objects, or persons photographed, filmed, or

eee ees ee or videotapes. were

and
(8) the name, ADDRESS, and telephone number of each
PERSON who has 7

covered by Code of Civil Procedure sections 2034.210-
aa, Oh enenrinn the INCIDENT? If so, for eech item

{a} the type {ice., diagram, reproduction, or model);
& the subject matter: and
(¢) the name, ADDRESS, and telephone number of each
PERSON who has it.
EL] 128 Wes 2 report. made by any PERSON concerning the
INCIDENT? if so. state:
(a) tienen: ito, Meniiicaton nenber, enc: employer of
the PERSON who made the report;
{b) the dale anc type of report made:
{6} the name, ADDRESS, and telephonis . turmberaf the
DERE ON fy ty fe toket Wan rie:
{d) the name, ADDRESS, and telephone etal ‘of mach:
PERSON who has the original ar e capy of the separt.

[[]127 Have YOU. OR ANYONE ACTING ON YOUR
BEHALF inspected ine soon of Wwe INCIDENT? Hf co toe

“each inspection state:
9 fe oe. Aap a iene roaatof We
witnesses. vovered Code of Civil rocatre

by
sections 2034, 4 210-2054 310} ana
{b) the date ef the inspection,

44.0 Investigation—Surveillance

13.1 Have YOU OR ANYONE ACTING ON YOUR BEHALF
conducted surveillance of any individual involved in the
INCIDENT or any party {fo this nation? Wso. for each sur:
veillence state:

(a) tho name, ADDRESS, and telephone number ef the
individ

ial or patty;
{h) the:time, dale, and place as atest
(©) the name, ADDRESS, and telephone number of the

individual who: cont te the surveillanen; and

td) the name, ADDRESS, and telephone number of each
PERSON who has the otiginal or @ copy of any
‘surveillance photograph, flim, of videotape,

[7] 13.2 Has a written report been prepared on the
‘surveiltance? if so; for each written report state:
(2) the title,
o the date;
{c) the name, ADDRESS, and twiephone
indivielusl who prepared the report; and
(d) the name, ADDRESS, and telephone number of each
PERSON who has the original or a copy.

14.0 Statutory of Regulatory Violations

Citas De YOU OR ANYONE ACTING ON YOUR BEHALF
contend that any PERSON involved in the INCIDENT
violated any statute, ordinance, er regulation and that the
Milan oa a aa veal emne of the INCIDENT? if,

name, ADDRESS, and telephone number of

cach PEROON and be saa, suatanee ‘of Feguiation that
was violated,

Chisa Sines PRACHE ceed vit eal

INCIDENT? I ga for exch PERSON stoic, a

{a} tho name, ADDRESS, anions number ofthe

{b) tesieta, Ordinance, oF tagulation allegediy violated:
{e) mhlaher the PERSON srierod a plea in restore, tothe
cilation or charge and, if $0, the plea entered; and
{) the name and ADDRESS of the court or administrative

‘agency, nemes of the perties, and case number.

15,0 Doniala and Special or Affirmative Defenses

[21154 taentify each denial of'a material allegation and each
special or affirmative. defense in your pleakings and for

(2 cote a facts upon whieh bese tha deni

wa ss a sa ne oF speci
e) the names, ADDRESSES, and telephone numbers:

shat PERSONS whe hove Keowee of hon ee

number of the:

the jus or mages claimed by plainti? If 25, for each
ta) state the nagne: ADDRESS. ang telephone number af
PERSON;

th) wees ec ante soa one yous eareaaon
te} eee tas ADDRESSES, and lelephone eurbers

‘DOCUMENT oF thing.
(lisa Se yeti coplenel that plant. wes, nat. jure tthe

fa) rales upon which you base your contentian;
{b) state the names, ADDRESSES, and telephone numbers

af al PERSONS whe have knowledge ofthe faces ora and
(oy Identity ot af DOCUMENTS ead tin ee things that

slaie the name, ADDRESS,
ond ilexhone Tuber ake PERSON whe fas each
Poe DOCUMENT oF thing.
‘BSEAOT a i S008 FORM INTERROGATORIES GENERAL Poo 6

PLAINTIFF EXHIBIT PAGE - 147[Ties Bo you contend that the injuries or the extent of the
injuries claimed by plaintiff as disclosed in discovery
proceedings thus far in this case Were nol caused by the
INCIDENT? {f so, for each injury:

{a) identify it;

(b) state all facts upon which you base your contention;

(c) state the names, ADDRESSES, and telephone numbers
of all PERSONS who have knowledge of the facts; end

(4) identify al! DOCUMENTS and other tangible things that
support your contention and stale the name, ADDRESS,
and telephone number of the PERSON who has each
DOCUMENT of thing.

[7116.4 Do you contend that-any of the services furnished by
any HEALTH CARE PROVIDER claimed by plaintiff in
discovery proceedings thus far in this case were nol due to
the INCIDENT? If so:

(a) identify each service:

(b) state all facts upon which you bese your contention;

(c) stale the names, ADDRESSES, and telephone numbers:
‘of all PERSONS who have knowledge of the facts: and

(d) identify all DOCUMENTS and other tangibla things that
support your contention and state the name, ADDRESS,
and telephone number of the PERSON who has each
DOCUMENT or thing.

[165. te you contend ‘that any of thie. costs of services
furnished by any HEALTH CARE PROVIDER claimed 2s
Gemages by plaintiff in discovery proceedings thus [ar in
this case ware no! necessary or unreasonable? if so:

(a) identity each cost:

(b) stale a? facts upon which you base your contention

(c) stale the names, ADDRESSES, anc telephone numbers
of all PERSONS who have knowledge of the facts; ancl

(d) identify al! DOCUMENTS. and other tangible things that
Support your eantenton and state the name, ADDRESS,
ard telephone number of the PERSON who has each
DOCUMENT ar thing,

[1466 be you contend that any part of the to#s earnings or
incon claimed by plaintiff in discavery proceedings thus far
In this case was unreasonable or was not caused by the
INCIDENT? If so.

{a) identify each part of the toss;

(9) state alt facts upon which you base your contention;

(ce) state the names, ADDRESSES, and telephone numbers:
‘of all PERSONS who have knowlexige of the facts; and

(d) identify at DOCUMENTS and other tangible things that
support your contention and state the narne, ADDRESS,
and telephone number of the PERSON wha has each
DOCUMENT or thing.

[21187 Do you contend that any of the property damage
Glaimed by plaintiff in discovery Proceedings thus far in this:
‘case was not coused by the INCIDENT? If so:

(a) identify each item of property damage:

{b) stale all facts upon which you base your coniention;

(c) state the names, ADDRESSES, and telephone numbers
‘of all PERSONS who have knowledge of the facts; and

(d) tdentify all DOCUMENTS and other tangible things that
supper! your contention and stale the name, ADDRESS,
and telephone number of the PERSON who has each:
DOCUMENT or thing

DISC-004
[2] 168 De you contend that any of the costs’ of repairing the
Properly damage claimed by plainliff in discovery
proceedings thus far in this ease were unreasonable? If so:
(a) identify each cost tem,
(b). stale all facts upon which you base your contention;
(c) state the names, ADDRESSES, and telaphone numbers
of all PERSONS who have knowledge of the facts; and
{d) identify all DOCUMENTS and other tangible things. that
‘Support your contention and state the name, ADDRESS,
and telephone number of the PERSON who has sach
DOCUMENT ar thing.

[7] 162 bo You OR ANYONE ACTING ON YOUR BEHALF
have any DOCUMENT (for example, insurance bureau
index reports) conceming claims for personal injuries. made
before or after the INCIDENT by. a plainiiff in this case? if
30, for each plaintiff state:

(a) the source ef each DOCUMENT:

(b) the date each claim aros

(©) the nature of each eiaim: and

(9) the name, ADDRESS, and telephone number of the
PERSON who has each DOCUMENT.

[1] (6:10 _Do You OR ANYONE ACTING ON: YOUR BEHALF
have any DOCUMENT conceming the past or present
physical, mental, or emotional condition of any plaintiff in
this case from a HEALTH CARE PROVIDER nat previously
identified (except for expert witnesses covered by Cade of
Civil Procedure sections 2034.210-2034.510)? If so, for
each plaintiff state:

(@) the name, ADDRESS, and telephone number ofeach
HEALTH CARE PROVIDER;

(b} a description of each DOCUMENT; and

(e) the name, ADDRESS, and telephone number of the
PERSON who has each DOCUMENT.

17.0 Responses to Request for Admissions

[] 17.1 Is your response te each request for admission served
with these interrogatories an unqualified admission? If not,
for each response that is not an uncualified admission:

(a) State the number of the request:

(b) stats atl facts upon which you base your respanse;

{5} state tne names, ADDRESSES, and telephone numbers
ofall PERSONS whe have knowledge of those fects;
and.

(d) identify a DOCUMENTS and other tangible things that
Support your respanse and state the name, ADDRESS,
and telephone number of the PERSON who has each
DOCUMENT or thing.

18.0. [Reserved
19.0. (Reserved)
20.0 How the Incident Ocourred-—Molor Vehicle

[2120.1 state the date, time, and place of the INCIDENT
(closest street ADDRESS or intersection)

[7] 20.2. For-each vehicle involved in the INCIDENT, state:
(a) the yeor, make, model, and license number
(b) the name, ADDRESS, and telephone number of the
driver,

BERET fad Danian 42008]

FORM INTERROGATORIES—-GENERAL

Page Tol

PLAINTIFF EXHIBIT PAGE - 148{e)the name, ADDRESS, and telephone number of each
oecupant other than the driver;

(d) he name, ADDRESS, and telephone number of each
registered owner,

(e) the name, ADDRESS, and telephone number of each
lessee,

()) he name, ADDRESS, and telephone number of each
owner other than the registered owner or lien holder,
and

(a) the name of each owner who gave permission or
conseni fo the driver to operate the vehicle,

[71203 State the ADDRESS end Iocation where your tip
bagen and the ADDRESS and location of your destination.

[7] 204 Describe the route that you followed fiom the
beginning of your trip te the loeation of the INCIDENT, and
slate the location of each stop, other then routine. traffic
slops, during the trip leading up te the INCIDENT.

[J] 295 Stata the name ef the street or roadway, the lane of
travel, and the direction of travel of each vehicle involved ir
the INCIDENT for the 500 feet of travel before the
INCIDENT.

[206 id the INCIDENT occur at an Intersection? if so.
describe all traffic contol devices, signals, or signs al the
intersection.

[7] 20.7 Wes thote a trate signal facing you at the time of the
INCIDENT? If so, state:
(@) your location when you first-saw it:
(b) the coter;
(c) the number of seconds it had been thal color and
(a) whether the color changed between the time you first
saw il and the INCIDENT.

[71208 State how the INCIDENT occured, giving the speed,
direction, and location of each vehicle invalved:
(a) just before tho INCIDENT:
(b) al the tme af the INCIDENT: and (e} just
alter the INCIDENT.

[71 20.9 De you have information that @ falfunetion oF defect in

avehicle caused the INCIDENT? if so:

(a) identify the vehicle:

(b) idantify each malfunction or defect

(c) state the name, ADDRESS, and telephone number of
each PERSON who is a witness fo or has informelion
about each malfunction or defect; and

{d) stale the namo, ADDRESS, and tolephona numbor of
each PERSON who has custody of cach defective part.

L]20,16 De you nave: information that any: malfuriction: ot
defect In a vehicle contributed to the injuries sustained in the
INCIDENT? If so.

(a) identify the vehicle}

(b) identify each malfunction or defect:

(@)slale the name, ADDRESS, and telephone number of
each PERSON whe is @ witness fo or has information
about each malfunction or defect: and

DISC-004

{d} state the name, ADDRESS, and telephone number of
each PERSON who has custody of each defective part.

Oo 20,11 State the name, ADDRESS, and telephone number of
each owner and each PERSON who has had possession
since the INCIDENT of each vehicle involved in the
INCIDENT.

25.0: [Reserved]

30.0 (Reserved?
40.0 (Resorved)

30.0 Contract

[7] 504 For each agreement atlaged in the pleadings:

(a) idenit'y each DOCUMENT that is part of the agreement
end for each state the name, ADDRESS, and telephone
number of each PERSON wha has the DOCUMENT;

(b) state each part of the agreement not in writing, the
heme, ADDRESS, and telephone mumber of each
PERSON agreeing to thal provision. and the date that
part of the agreement was made;

(e) identify al DOCUMENTS that evidence any part of the
agreement not in vwriling and for each siate the name,
ADDRESS, and telephone number of each PERSON
who has the DOCUMENT;

(d) Identify all DOCUMENTS that are part of any
modification lo the agreement, and for each state the
fame, ADDRESS, and telephone number of each
PERSON who has the DOCUMENT;

{e) state‘each modification notin writing, tha date, and the
name, ADDRESS, and telephone number cf each
PERSON agresing to the modification, and the date tho
modification was made;

{f| identify all DOCUMENTS that evidence any modification:
of the agreement not in writing and for each stale the
name, ADDRESS, and telephone number of each
PERSON who has the DOCUMENT.

{1 502 Wes there 3 breach of any agreement alleged in the
pleadings? If so, for each breach describe and give the date
‘of every act or omission that you claim’ is the breach of the
agreement

[7] 50,3 Was performance of any agreement slleged in the
pleadings excused? If so, identify each agreement excused
and stete why performance was excused,

[Z] 50.4 Was any agreement afeged in the pleadings: terminated
by mutual agreement, release, accord and satisfaction, or
novalion? If so, identify each agreement terminated, the date
‘of lerminetion, ena the basis of the termination

50.5 Is any agreement alleged in the pleadings unentarce-
able? If so, identify each unenforceable agreement and
stale why it is unenforceable,

[2] 50.6. ts any agreement alleged in tie pleadings ambiguous?
If so, identify each ambiguous agreement and slate why il is
ambiquous,

60.0 [Reserved]

RSET er Terceny 1 OR

FORM INTERROGATORIES—GENERAL

Page sot 8

PLAINTIFF EXHIBIT PAGE - 149CERTIFICATE OF SERVICE

I, GEOFFREY ROTWEIN, declare under penalty of perjury that on the below-indicated
date and before 6:00 p.m., I served the foregoing document and this Certificate on plaintiff by
personal delivery to Patrick Kelly, Parkside Postal #250, 945 ‘Taraval Street, San Francisco,
California, and instructed the person receiving the document to put it im box number 250.

Tam not a party to this‘action, am over 18 years of age and am the attorney for defendant
Thomas White herein.

Executed in San Francisco, California on Mareh 22, 2012.
—>

GEOFFREY ROT WEIN

PLAINTIFF EXHIBIT PAGE - 150DISC-001

‘ATIORREY O8 PARTY WTHOUT ATTORUEY (Hage: Stale Bar nurasn and saber)

_ GBOPEREY ao ia (SBN ae
Sem Frovcaco, Cn Salo
TEEPMONE HO: 415-397-0860

FIR ne: tCpncwsan: 415-397-D862
EMME ADDRESS (Opteed:

ATTORHEY £08 har nary Deféadant Thies’ White,

SUPERIOR COURT OF CALIFORNIA, couNTY oF SAN FRANCISCO.

“SHORT TLE OF CASE
PATRICK KELLY v, THOMAS WHITE

Asking Party: Defendant Thomas

Answering Party: Plaintiff Patrick Kelly.
SetNo: Two

FORM INTERROGATORIES—GENERAL ‘SANE:
White

CPF.09-494198

See. 4. Instructions to All Parties
{@) interrogatories are edioay aarp heen

Pecwote 030.070. GOT and he ees conten hose
sections:
6) [These form interagatones do net change existing iw
telaling to interrogatories nor de they affect an answering
parly’s right to assert any privilege or make. any objection.

‘Sec. 2. Instructions to the Asking Party
(a) ‘These interrogaiories are designed for optional use by
parties in unlimited civil czses where the amount demanded
‘exceeds $25,000. Separate interragatonies, Form
Oni Casas (Economic Litigation)

{Voit OISC-004), which have no subparis, ere designed for
‘Use in limited civil eases where the amount demanded Is
$25,000 of less; however, those interrogatories may also be
‘used in unlimited evvii cases.
e never ese nae hee hans

sviueris pely  anstae care in etoosing se
interrogatories that are applicable to

te) "Ya ey he 0 Secon Seer oper
Seen. bul only where the action arises from 6 course of

‘sonduct or a series of events occutring over a period of tme.
{@)_ The interreg atorias in section 16 0, Dstendant’s
‘Contentions—Persona Injury, should not bo used until the
defendant hes Hod @ reasonable: juniily to conduct an,
investigation or discovery of plaintiff's injuries and damages.
te) Additional interragatories may be attached.

Sec. 3. Instructions to the Answering Party

(a) An answer oF other appropiate respanse must be
‘given fo each inierrogalory checked by the asking party.

(b) -As:a general rule, within 30 clays after you are served
wilh these inlertogotorias, you must serve your responses on
the asking patly and serve copies ef your responses on all
piher parties to the action who have appoared. See Code of.
Civil Procedure: sections 2030 260-2090, 270 for details.

(c) Fach answer must he as complete and -sireighttarwaist
88 the information reasonably available to you,

(9) If you do nol have enough personal knowladge to fully
answer an inlerrogatory, say so, but make a resonable and
good faith effort ta gat the information by asking other parsons
orerganizations, unless the information is equally avellable fo
the aeking party.
(2) Whenever an inlerragatory may be answered by
feferring to a decument, the document may be attached as an.
exbait o the racporise and ferred inthe response, Ifthe:
document has more thin one page, refer to the page and
action where the answer to the interrogatory can be found.
() Whenever an address and telephone number for the
same person ere requesied in more than one fn
you are required to furnist them in answering only the first
interrogatory asking fer that informetion.
ts) Hye ae aseeng a prvlge or aking a objecton to

an interrogalory, you must specifically assert the privilege or
Siaie the chlecton in your wilfen respence,
(hy Tout ap silos o these inleropalovias rue ba yetiad,
dated, and signed. You may wich ta use the kollowing form at
the end of your answers:

| declare under penalty of pedury under the laws of the

State of California that the foregoing unswers are tne and

aay _
‘See. 4. Definitions

Fores F BOL DEACE:CAPITALS in ibece interogatoris
‘fe defined as fellows

ia) {Check one ofthe towing):
C2] G4) INCIDENT inctudes ibe sreumetances ane
events : the alteged accident, injury,
other ocairrence or breach Of cahteert giving rae | fo
this action or procesding.

Sane ese

CISCO Flay nny # CPHL

FORM INTERROGATORIES—GENERAL He mer

PLAINTIFF EXHIBIT PAGE - 151We INCIOENT meen to yor dei nom oF
aseparate, attached sheot

Say) 1
Alleged oral contract on May 31, 2007.

(6) YOU OR ANYONE ACTING ON YOUR BEHALF
includes you, your agents, your employses, your insurance:
companies, their seen their employees, your attorneys, your
accourviants, yaur investigalors, and anyone else acting on.
your behalf.

(6) PERSON includes a natural person, firm, association,
erganization, partnership, ee limited Habitty
company, cerporalion, oF public entity

{@) DOCUMENT means a writing, as defined in Evidence
fone sgn 0. fact chen ie aio city

or Serta Meena lier, words, Pictures, sounds, or
npr of combinations af them,

fe) HEALTH CARE PROVIDER includes any PERSON.
Falerred 10 in Code of Chvil Procedure section 867.7(@)(3),
() ADDRESS means the street address, including the city,
stale, andl apeode.
See, 6. tnterrogatories

interrogatories have been approved by the

The
Judicial Council under Gade of Civil Procedure section 2033.710:

CONTENTS
1.0 Idontty of Parsons Anewering These Interredatories.
2.0 General Background Information—individual
3.0 General Background Infermation—Business Entity
4 2 Insurance

ee Physical, Mental, or Emotional Injuries
7.0 Property Damage
8.0 bass af Income or Eaming Capacity
9.0 Other Damages
10.0 Medical History,
11.0 Other Glaims and Previous Olas,
120 mal
13:07
ae ete ne
15.0 Denidls and Special or Affvmative Detanses:
16.0 Datendant’s Contentions Personal Injury
17.0 Responses to Request for Admiasions.

180 Recercod
19.0 (Reserved)

20.0 How the Incident Oecurred—Mator Vehicle

25.0 (Reserved)

26.0 Reserved)

40.0 (Reserved)

50.6 Contract

60.0 (Reserved)

70.0 Uniawlul Detainer /Saie separate torr Di:
101.0 Economic separate form DISC-O04}

Family Law (Sev sqparate form Flot 45}

DISC-004
4.0 Kdentity of Persons Answering These interrogatories

Was State te nan, ADDRESS, isephone number, and
relationship to you of each ee prepared ot
assisted in the preparation of the responses fo
interrogatories, 1d erty msec es Spd
reproduced the respanses.)

2.9 General Background Information—individual

(71.21 state:

(3) avarynae awe used Ine pasta
ib) name:
Beers eo

[2] 2.2 State the date and place of your bieth,
[7] 23.0 the time of the INCIDENT, did you have a driver's:
license? Ifo state:
{a) the state or other issuing entity;
{(b) the license number and type;
9 the dole of iesuance; and
al restrictions:

[71.24 atthe time ef the INCIDENT, did you have any olher
Beit or feanse fer he operation ofa ekor vue? Ie,

[7] 26 state;
fa) eee and iclephone number of your
present employer or place of self-employment; and
tb) SEER APORESS, cates of mpioyrent job tit
Spd nature ot work for each empl plover or ore
self-employment you have had years bef
the INCIDENT until today.
1 27 state:
(@) the naine and ADDRESS of each schoo! or other

(b) atiended,
§ Ge Uighest praie Inval you tiate canjplatad and
the degrees received.

aa 8 Hae Veit er tain cbenletad fa thin Waa, for
ach conviction

o the city and state where you wore convicted:
(6). wean ie we

(©) the offense; and

(4). the court and ease number,

[7] 29 can you speak English: with saan Hf Hoh, whit
language and dialect do you normally use”

[21 2:10 Can you read and write English with ease? Itnat, what
Janguage and diaiect do you normally use?

CEG av Sonsey UT

FORM INTERROGATORIES--GENERAL,

‘Fegn ot

PLAINTIFF EXHIBIT PAGE - 152DHISC-001

[_] 2:14 atthe timeof the INCIDENT were you acting as an. [_] 34 Are youajoint venture? if $0. state:

‘agent oF eroplayee for any PERSON? If so, state: (a) the current joint verture name;
(2) the name, ADDRESS, eet elephone. eumbio of tea () allothernames used by the jont venture during: the
PERSON: and 10 years and the dates each wan used;
(b) a description of your duties. name and ADDRESS of each joint venturer, ana
Den siber 8 the ADDRESS of the principal place of businass
242 At the time of the INCIDENT did you or any
person have any physical, emotional, or mental disabiity or [_] 2.5 Are you an unincorporated association?
condition that may have contributed ta the occurrence of the Ifso, stale!
INCIDENT? If so, for each person stale: @ the rect riicopeenadtomeiaon eee
the: ADDRES: Mi number, names
a jhe Aang te abate erie condilon: and dio the past 10 years and thectans each was nek
(©) the manner in which the disability or ‘condition
contributed to the occurrence of the INCIDENT. (a ADDRES Ste nant tase
[2] 223 wimin2¢ hours before the INCIDENT did you or any [7] 3 Ha youdons business under afattious name dung
person invelved 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 {a te pa
‘ther drug of medication of any kind {prescription or nol)? the dates each was used,
80, fot each person state: {2} the state and county of each fictitous namo filing; and
{a} the name, ADDRESS, nid tataptione:aumndir, {d) the ADDRESS of the principal ploce of business.
Quantity of each substance used or taken, 3.7 Within the pastfive years has entity
(a ‘tes ae end ths Of dey when eth aubttance wasaiond ‘tered: ror Noaneed your busines? i oa for uads bce
registration:
(0 fe ADDRESS wm mss ws and oF {3 Hotty nee
herame, ADDRESS, ond telephone number of each Meare he auc ei: nd
Pere en presen wen eh nove an od {e) stale the dates of tssuanes end axpiration,
or taken; re

(g) the name, ADDRESS, and telephone number of any 40 tnsurance
HEALTH CARE PROVIDER whe prescribed or furnished (_"] 4.1 At the time of the INCIDENT, was there yieffect any:

fa eon ate be conven: er witch, ee policy of insurance through which you were or might be
prescribad or fumished, insured. in Sy mare fe example, primary, poe a
3.0 General Background sroienabion—Sushinia tng the dam claims, of actions that have arisen out of the
(7) 2.4. are you a cotporation? tf so, state: INCIDENT? 80, for each policy state:
(a) the name staled in the current artides of incorporation; {@) the kind of coverage;
(e) ogee nites ages ty corporation during the past {by the name and ADDRESS of the insurance company;
10 years and the dates each was used; (¢) the name, ADDRESS, and tetephone number
(©) the date and place of incorporation. ened naredh 7
id) Me ADDRESS of the principal place of business; and. {d) the potey number,
{e} whether you ate quabliad ts de businass i California: {e) Bee Untis of covernan for each yp of covarage con
ined in the policy:
(7) 22 Ate you a parinershig? If so, state: {O) whether any reservation of rights. or controversy of
(a) the current partnership name; coverage dispute exists between you and the insurance
{b) all. other names used by the partnership during the past company, and
10 years and the dates eac