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California Interrogatories and Requests for Production - Personal Injury

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This form is a sample set of interrogatories and requests for production propounded to defendant by the plaintiff in a personal injury action.

California Interrogatories and Requests for Production — Personal Injury are legal documents used during the pretrial discovery process in a personal injury case. These documents are typically served by one party (the propounding party) to the opposing party (the responding party) to gather crucial information and evidence related to the personal injury claim. Interrogatories are a set of written questions that the propounding party asks the responding party. They aim to obtain detailed information about the incident, injuries sustained, medical treatments, witnesses, and any other relevant facts. Interrogatories can be highly effective in uncovering valuable details and identifying potential strengths or weaknesses in the opposing party's case. Requests for Production, on the other hand, are documents that the propounding party asks the responding party to produce. These may include medical records, photographs, police reports, insurance policies, or any other relevant documents that could help establish liability or damages in a personal injury claim. In personal injury cases in California, there are various types of Interrogatories and Requests for Production commonly used. Some examples include: 1. Interrogatories — Plaintiff to Defendant: These are questions posed by the injured party (plaintiff) to the party allegedly responsible for the injury (defendant). The interrogatories aim to extract information regarding the defendant's liability, negligence, and any potential defenses. 2. Interrogatories — Defendant to Plaintiff: In this scenario, the defendant serves interrogatories on the plaintiff. The defendant seeks information related to the plaintiff's injuries, medical treatment, prior medical history, prior accidents, and any other relevant details that may impact the plaintiff's claims or damages. 3. Interrogatories — General: These interrogatories are used more broadly and can be served by either party. They typically cover general inquiries regarding the incident, witnesses, damages, and other relevant factors. 4. Requests for Production — Medical Records: The propounding party may specifically request the responding party to produce medical records related to the injuries sustained in the personal injury case. These records can help establish the extent and nature of the injuries suffered by the plaintiff. 5. Requests for Production — Accident Reports: The propounding party may ask the responding party to provide accident reports from law enforcement agencies, such as police reports or incident reports, which could contain valuable evidence supporting the personal injury claim. 6. Requests for Production — Insurance Information: The propounding party may request the responding party to produce relevant insurance policies, coverage details, and any communications between the responding party and their insurance carrier. Using California Interrogatories and Requests for Production — Personal Injury can be a vital step in gathering evidence and building a strong case in a personal injury claim. These documents play a pivotal role in uncovering important facts, clarifying liability, assessing damages, and preparing for trial or settlement negotiations.

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FAQ

You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.

(a) A defendant may propound interrogatories to a party to the action without leave of court at any time. (b) A plaintiff may propound interrogatories to a party without leave of court at any time that is 10 days after the service of the summons on, or appearance by, that party, whichever occurs first.

In a limited civil case (cases less than $25,000) you may ask each party only 35 discovery questions total, whether they are form interrogatories, special interrogatories, requests for admission, or requests for production of documents.

These are typically requests that are not relevant, unduly burdensome, broad, vague, privileged. or protected by the work product doctrine.

(b) Except as provided in Section 2030.070, no party shall, as a matter of right, propound to any other party more than 35 specially prepared interrogatories. If the initial set of interrogatories does not exhaust this limit, the balance may be propounded in subsequent sets.

Rule 33(a), Federal Rules of Civil Procedure, restricts to 25 (including all discrete subparts) the number of interrogatories a party may serve on any other party. Leave of court, which is not routinely given absent stipulation, is required to serve more than 25 interrogatories cumulatively.

If your case is an unlimited civil case (over $25,000) you may ask up to 35 special interrogatories, but may ask more with a declaration explaining the need for additional requests and a statement that the request is not done for an improper purpose.

Interrogatories, which are written questions about things that are relevant or important to the case. (NRCP 33; JCRCP 33) Requests for production of documents or things, which are written requests that demand the other side provide particular documents or items. (NRCP 34; JCRCP 34.)

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Fill out the basic information. Some tips and definitions of terms that may help you fill out page 1 of the form: Where it says "Attorney for," write “Self ... To ask the other side to produce documents or permit inspection of physical evidence, you can use Request for Production. Interrogatories. Ask the other side to ...This guide contains forms and instructions for responding to Requests for Production from your opponent in a California civil case. PLAINTIFF [CLIENT'S NAME] (“PLAINTIFF”), requests that Defendant. [DEFENDANT'S NAME] (“DEFENDANT”) identify, produce and permit the inspection. Complete Your Responses to the Interrogatories​​ Immediately after the top caption, your response must include the name of the requesting party, the responding ... This article covers Special Interrogatories and Judicial Council-approved Form Interrogatories. Covered elsewhere will be our discussion on Requests for ... A request for production allows you to obtain a copy of all documents and evidence in the other parties' possession, custody, or control. Although the document ... A request for production of documents is used in the discovery process for personal injury cases. Learn how to respond to this discovery ... Although this checklist is not a complete list, it does identify the most commonly used objections to discovery requests: 1. Irrelevant. Use this objection ... Sample requests for production of documents in personal injury cases. Free example RPDs for car accident, medical malpractice, and other personal injury ...

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California Interrogatories and Requests for Production - Personal Injury