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Sample Interrogatories Insurance Company document sample
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Note: IF A QUESTION DOES NOT APPLY TO YOUR SCOPE, INDICATE “NOT APPLICABLE”
1
Attorneys for Cross-Defendant/Cross-Complainant,
2 (INSERT NAME OF COMPANY)
3
4 ** THIS DOCUMENT HAS BEEN CREATED AND SAVED CONTAINING THE
INTEROGATORY RESPONSES THAT REMAIN CONSTANT FOR OUR COMPANY.
5 FOR ANY QUESTION IN WHICH THE RESPONSE WILL VARY BY PROJECT, THAT
SECTION HAS BEEN LEFT BLANK. THE INTENT OF THIS DOCUMENT IS TO
6 PROVIDE PRELIMINARY DRAFT INFORMATION TO COUNSEL FOR USE IN
PREPARING THE ACTUAL CASE/PROJECT SPECIFIC DOCUMENT **
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF SACRAMENTO
10
11 ) Case No.
Defendants. LEAVE BLANK ) (INSERT COMPANY NAME)
12 ) RESPONSES TO CASE MANAGEMENT
) ORDER RE: INTERROGATORIES -
13 (INSERT NAME OF COMPANY) )
Cross-Complainant, ) Complaint Filed: LEAVE BLANK
14 )
v. )
15 )
)
16 Cross-Defendants. )
)
17 )
)
18 )
)
19 )
)
20 )
)
21 )
)
22 )
)
23
24 PROPOUNDING PARTY: CASE MANAGEMENT ORDER
25 RESPONDING PARTY: (INSERT COMPANY NAME)
26 SET NO.: ONE
27 ///
28 ///
BREMER WHYTE BROWN &
(INSERT COMPANY NAME) RESPONSES TO CASE MANAGEMENT ORDER RE:
O’MEARA LLP INTERROGATORIES
20320 S.W. BIRCH STREET
SECOND FLOOR
NEWPORT BCH, CA 92660
(949) 221-1000 C:\Docstoc\Working\pdf\f872f0d1-df6d-456d-8aae-74b37f62e1d9.doc
1 PRELIMINARY STATEMENT
2 These responses are made solely for the purpose, and in relation to this action. Each
3 response is given subject to appropriate objections (including but not limited to objections
4 concerning competency, relevancy, materiality, propriety, and admissibility) which would require
5 the exclusion of any statement contained herein if the interrogatory were asked of or any statement
6 contained herein were made by, a witness present and testifying in a court. All such objections and
7 grounds therefore are reserved and may be interposed at the time of trial.
8 This responding party has not completed its investigation of the facts relating to this action,
9 has not yet completed discovery in this action, and has not yet completed preparation for trial. The
10 following answers are therefore given without prejudice to this party's right to allege and/or
11 produce evidence of any subsequently discovered facts or circumstances.
12 All responses must be construed as given on the basis of recollection, discovery is not yet
13 complete and all responses are based solely upon such information presently available and
14 specifically known to the defendant. It is anticipated that further discovery, investigation, and
15 analysis will supply additional facts, add meaning to known facts, as well as establish entirely new
16 factual conclusions and legal contentions, all of which may necessitate substantial additions,
17 changes, or variations to the responses hereinafter set forth.
18 Except for facts explicitly admitted herein, no admission of any nature is to be implied or
19 inferred. The fact that any interrogatory herein has been answered should not be taken as an
20 admission, or confession of the existence of any facts set forth or assumed by such special
21 interrogatory or that such response constitutes evidence of any fact thus set forth or assumed. All
22 responses must be construed as given on the basis of recollection.
23 These preliminary comments shall apply to each and every response given herein, and shall
24 be incorporated by reference as though fully set forth in all of the responses appearing in the
25 following pages.
26 Cross-Defendant/Cross-Complainant, (INSERT COMPANY NAME), hereby responds to
27 Case Management Order Special Interrogatories as follows:
28 ///
BREMER WHYTE BROWN &
2
O’MEARA LLP
20320 S.W. BIRCH STREET
(INSERT COMPANY NAME) RESPONSES TO CASE MANAGEMENT ORDER RE:
SECOND FLOOR INTERROGATORIES
NEWPORT BCH, CA 92660
(949) 221-1000
1 RESPONSES TO INTERROGATORIES
2 SPECIAL INTERROGATORY NO. 1:
3 Are YOU a corporation? If so, state:
4 (a) The named stated in the current articles of incorporation;
5 (b) All other names used by the corporation during the past ten years and the dates each
6 was used;
7 (c) The date and place of incorporation;
8 (d) The address of the principal place of business;
9 (e) Whether YOU are qualified to do business in California.
10 ///
11 RESPONSE TO SPECIAL INTERROGATORY NO. 1:
12 (INSERT YOUR RESPONSES FOR EACH OF THE QUESTIONS ABOVE)
13 (a)
14 (b)
15 (c)
16 (d)
17 (e)
18 ///
19 SPECIAL INTERROGATORY NO. 2:
20 Are YOU a partnership? If so, state:
21 (a) The current partnership name;
22 (b) All other names used by the partnership during the past ten years and the dates each
23 was used;
24 (c) Whether YOU are a limited partnership and, if so, under the laws of what
25 jurisdiction;
26 (d) The name and address of each general partner;
27 (e) The address of the principal place of business.
28 ///
BREMER WHYTE BROWN &
3
O’MEARA LLP
20320 S.W. BIRCH STREET
(INSERT COMPANY NAME) RESPONSES TO CASE MANAGEMENT ORDER RE:
SECOND FLOOR INTERROGATORIES
NEWPORT BCH, CA 92660
(949) 221-1000
1 RESPONSE TO SPECIAL INTERROGATORY NO. 2:
2 (INSERT YOUR RESPONSES FOR EACH OF THE QUESTIONS ABOVE OR
3 ENTER “NOT APPLICABLE”)
4 ///
5 SPECIAL INTERROGATORY NO. 3:
6 Are YOU a joint venture: If so, state:
7 (a) The current joint venture name;
8 (b) All other names used by the joint venture during the past ten (10) years and the dates
9 each were used;
10 (c) The name and address of each joint venture;
11 (d) The address of the principal place of business.
12 ///
13 RESPONSE TO SPECIAL INTERROGATORY NO. 3:
14 (INSERT YOUR RESPONSES FOR EACH OF THE QUESTIONS ABOVE OR
15 ENTER “NOT APPLICABLE”)
16 (a)
17 (b)
18 (c)
19 (d)
20 ///
21 SPECIAL INTERROGATORY NO. 4:
22 Are YOU an unincorporated association? If so, state:
23 (a) The current unincorporated association name;
24 (b) All other names by the unincorporated association during the past ten (10) years and
25 the dates each was used;
26 (c) The address of the principal place of business.
27 ///
28 ///
BREMER WHYTE BROWN &
4
O’MEARA LLP
20320 S.W. BIRCH STREET
(INSERT COMPANY NAME) RESPONSES TO CASE MANAGEMENT ORDER RE:
SECOND FLOOR INTERROGATORIES
NEWPORT BCH, CA 92660
(949) 221-1000
1 RESPONSE TO SPECIAL INTERROGATORY NO. 4:
2 (INSERT YOUR RESPONSES FOR EACH OF THE QUESTIONS ABOVE OR
3 ENTER “NOT APPLICABLE”)
4 (a)
5 (b)
6 (c)
7 ///
8 SPECIAL INTERROGATORY NO. 5:
9 Have YOU done business under a fictitious name during the past ten (10) years? If so, for
10 each fictitious name, state:
11 (a) The name;
12 (b) The dates each were used;
13 (c) The state and county of each fictitious name filing; the address of the principal place
14 of business.
15 ///
16
RESPONSE TO SPECIAL INTERROGATORY NO. 5:
17
(INSERT YOUR RESPONSES FOR EACH OF THE QUESTIONS ABOVE OR
18
ENTER “NOT APPLICABLE”)
19 (a)
20 (b)
21 (c)
22 ///
23 SPECIAL INTERROGATORY NO. 6:
24 Within the past five (5) years has any public entity registered or licensed YOUR business?
25 If so, for each license registration:
26 (a) identify the license or registration;
27 (b) state the name of the public entity;
28
BREMER WHYTE BROWN &
5
O’MEARA LLP
20320 S.W. BIRCH STREET
(INSERT COMPANY NAME) RESPONSES TO CASE MANAGEMENT ORDER RE:
SECOND FLOOR INTERROGATORIES
NEWPORT BCH, CA 92660
(949) 221-1000
1 (c) state the dates of issuance and expiration;
2 RESPONSE TO SPECIAL INTERROGATORY NO. 6:
3 (1.) Contractor’s License
4 (a) Contractor’s License, License Number (ENTER YOUR LICENSE #)
5 (b) State of California Contractors License Board
6 (c) Issued on (ENTER DATE); Expires on (ENTER DATE)
7 (2.) California License to do Business
8 (a) Business License, Number (ENTER YOUR LICENSE #)
9 (b) California Secretary of State
10 (c) Issued on (ENTER DATE); Expires on (ENTER DATE)
11 ///
12 SPECIAL INTERROGATORY NO. 7:
13 Please provide the last known name, address and telephone number of the person or persons
14 most knowledgeable regarding the LABOR and/or SERVICES YOU performed for the PROJECT,
15 and state whether this person or persons is currently employed by YOU:
16 (a) With respect to the bidding and contracting for the LABOR and/or SERVICES
17 YOU performed on the PROJECT;
18 (b) With respect to the LABOR and/or SERVICES performed at the PROJECT.
19 ///
20 RESPONSE TO SPECIAL INTERROGATORY NO. 7:
21 (THIS INFORMATION MAY VARY BY PROJECT – IF ALWAYS THE SAME
22 ENTER YOUR RESPONSE HERE)
23 (a)
24 (b)
25 SPECIAL INTERROGATORY NO. 8:
26 Please provide the name, address, and telephone number of the current owner, partner,
27 managing agent, or employee who is most knowledgeable regarding the LABOR and/or
28 SERVICES YOU performed at the PROJECT.
BREMER WHYTE BROWN &
6
O’MEARA LLP
20320 S.W. BIRCH STREET
(INSERT COMPANY NAME) RESPONSES TO CASE MANAGEMENT ORDER RE:
SECOND FLOOR INTERROGATORIES
NEWPORT BCH, CA 92660
(949) 221-1000
1
2 RESPONSE TO SPECIAL INTERROGATORY NO. 8:
3 (THIS INFORMATION MAY VARY BY PROJECT – IF ALWAYS THE SAME
4 ENTER YOUR RESPONSE HERE)
5 ///
6 SPECIAL INTERROGATORY NO. 9:
7 Identify YOUR job foreman/construction supervisor for the PROJECT, providing name,
8 last known address and telephone number, and state whether this person is currently employed by
9 YOU.
10 ///
11 RESPONSE TO SPECIAL INTERROGATORY NO. 9:
12 (THIS INFORMATION MAY VARY BY PROJECT – IF ALWAYS THE SAME
13 ENTER YOUR RESPONSE HERE)
14 ///
15 SPECIAL INTERROGATORY NO. 10:
16 Provide the name, title, last known address and telephone number of the person at your
17 company at the time YOU performed YOUR LABOR and/or SERVICES at the PROJECT who
18 was responsible for obtaining YOUR insurance policies and additional insured endorsements, and
19 state whether this person is currently employed by YOU.
20 ///
21 RESPONSE TO SPECIAL INTERROGATORY NO. 10:
22 (THIS INFORMATION MAY VARY BY PROJECT – IF ALWAYS THE SAME
23 ENTER YOUR RESPONSE HERE)
24
25 SPECIAL INTERROGATORY NO. 11:
26 What LABOR and/or SERVICES did YOU perform on the PROJECT pursuant to a written
27 contract, change orders and/or extra?
28 ///
BREMER WHYTE BROWN &
7
O’MEARA LLP
20320 S.W. BIRCH STREET
(INSERT COMPANY NAME) RESPONSES TO CASE MANAGEMENT ORDER RE:
SECOND FLOOR INTERROGATORIES
NEWPORT BCH, CA 92660
(949) 221-1000
1 ///
2 RESPONSE TO SPECIAL INTERROGATORY NO. 11:
3 (THIS INFORMATION MAY VARY BY PROJECT – IF ALWAYS THE SAME
4 ENTER YOUR RESPONSE HERE)
5 ///
6 SPECIAL INTERROGATORY NO. 12:
7 What LABOR and/or SERVICES did YOU perform on the PROJECT pursuant to a oral
8 contract, change orders and/or extra?
9 ///
10 RESPONSE TO SPECIAL INTERROGATORY NO. 12:
11 (THIS INFORMATION MAY VARY BY PROJECT – IF ALWAYS THE SAME
12 ENTER YOUR RESPONSE HERE)
13 ///
14 SPECIAL INTERROGATORY NO. 13:
15 What LABOR and/or SERVICES did YOU perform on the PROJECT pursuant to an
16 implied contract, change orders and/or extra?
17 ///
18 RESPONSE TO SPECIAL INTERROGATORY NO. 13:
19 (THIS INFORMATION MAY VARY BY PROJECT – IF ALWAYS THE SAME
20 ENTER YOUR RESPONSE HERE)
21 ///
22 SPECIAL INTERROGATORY NO. 14:
23 With what PERSON did YOU contract to perform the above-described work?
24 ///
25 RESPONSE TO SPECIAL INTERROGATORY NO. 14:
26 (THIS INFORMATION MAY VARY BY PROJECT – IF ALWAYS THE SAME
27 ENTER YOUR RESPONSE HERE)
28 ///
BREMER WHYTE BROWN &
8
O’MEARA LLP
20320 S.W. BIRCH STREET
(INSERT COMPANY NAME) RESPONSES TO CASE MANAGEMENT ORDER RE:
SECOND FLOOR INTERROGATORIES
NEWPORT BCH, CA 92660
(949) 221-1000
1 ///
2 SPECIAL INTERROGATORY NO. 15:
3 Did YOU supply materials to the PROJECT?
4 ///
5 RESPONSE TO SPECIAL INTERROGATORY NO. 15:
6 (INSERT YOUR RESPONSE FOR THE QUESTION ABOVE)
7 ///
8 SPECIAL INTERROGATORY NO. 16:
9 If YOU supplied materials, describe the materials YOU provided and state the first and last
10 dates on which YOU supplied materials.
11 ///
12 RESPONSE TO SPECIAL INTERROGATORY NO. 16:
13 (THIS INFORMATION MAY VARY BY PROJECT – IF ALWAYS THE SAME
14 ENTER YOUR RESPONSE FOR THE QUESTION ABOVE OR INSERT “NOT
15 APPLICABLE”) Discovery and investigation are continuing. Responding Party reserves the
16 right to supplement this response.
17 ///
18 SPECIAL INTERROGATORY NO. 17:
19 If YOU supplied materials, state to what person(s) or entity(ies) you provided them, and
20 provide their last known address and telephone number.
21 ///
22 RESPONSE TO SPECIAL INTERROGATORY NO. 17:
23 (THIS INFORMATION MAY VARY BY PROJECT – IF ALWAYS THE SAME ENTER
24 YOUR RESPONSE HERE)
25 SPECIAL INTERROGATORY NO. 18:
26 Did YOU contract any of the work that was to be performed by YOU on the project to
27 another person or entity?
28 ///
BREMER WHYTE BROWN &
9
O’MEARA LLP
20320 S.W. BIRCH STREET
(INSERT COMPANY NAME) RESPONSES TO CASE MANAGEMENT ORDER RE:
SECOND FLOOR INTERROGATORIES
NEWPORT BCH, CA 92660
(949) 221-1000
1 ///
2 RESPONSE TO SPECIAL INTERROGATORY NO. 18:
3 (THIS INFORMATION MAY VARY BY PROJECT – IF ALWAYS THE
4 SAME ENTER YOUR RESPONSE HERE)
5 ///
6 SPECIAL INTERROGATORY NO. 19:
7 If YOU contracted any of YOUR work to another, person(s) or entity(ies) to whom YOU
8 contracted, providing their last known address and telephone number.
9 ///
10 RESPONSE TO SPECIAL INTERROGATORY NO. 19:
11 (THIS INFORMATION MAY VARY BY PROJECT – IF ALWAYS THE
12 SAME ENTER YOUR RESPONSE HERE)
13 ///
14 SPECIAL INTERROGATORY NO. 20:
15 If YOU contracted any of YOUR work to another, state which portions of that contract
16 was in writing, oral, and/or implied in fact? .
17 ///
18 RESPONSE TO SPECIAL INTERROGATORY NO. 20:
19 (THIS INFORMATION MAY VARY BY PROJECT – IF ALWAYS THE SAME
20 ENTER YOUR RESPONSE HERE)
21 ///
22 SPECIAL INTERROGATORY NO. 21:
23 If YOU did contract any of YOUR work to another, state what work and/or services YOU
24 so contracted.
25 RESPONSE TO SPECIAL INTERROGATORY NO. 21:
26 (THIS INFORMATION MAY VARY BY PROJECT – IF ALWAYS THE
27 SAME ENTER YOUR RESPONSE HERE)
28 ///
BREMER WHYTE BROWN &
10
O’MEARA LLP
20320 S.W. BIRCH STREET
(INSERT COMPANY NAME) RESPONSES TO CASE MANAGEMENT ORDER RE:
SECOND FLOOR INTERROGATORIES
NEWPORT BCH, CA 92660
(949) 221-1000
1 ///
2 SPECIAL INTERROGATORY NO. 22:
3 Between January 1, 1995, and the present, was there in effect any policy of insurance
4 through which YOU were or might be insured in any manner (for example, primary, pro rata, or
5 excess liability coverage) for the DAMAGES, claims or actions alleged in this action? If so, for
6 each policy, state the kind of coverage. A copy of the policy or policies shall be deposited in the
7 Document Depository.
8 ///
9 RESPONSE TO SPECIAL INTERROGATORY NO. 22:
10 (INSERT YOUR RESPONSE FOR THE QUESTION ABOVE AND PROVIDE AN
11 INSURANCE COVERAGE MATRIX CONTAINING ALL OF THE INFORMATION
12 HIGHLIGHTED UNDER NO. 22 - 26 FOR PREPARATION OF THE “STATEMENT OF
13 INSURANCE”) See Responding Party’s responses to Statement of Insurance.
14 ///
15 SPECIAL INTERROGATORY NO. 23:
16 Between January 1, 1995, and the present, was there in effect any policy of insurance
17 through which YOU were or might be insured in any manner (for example, primary, pro rata, or
18 excess liability coverage) for the DAMAGES, claims or actions alleged in this action? If so, for
19 each policy, state the name, address of the insurance company.
20 ///
21 RESPONSE TO SPECIAL INTERROGATORY NO. 23:
22 See Responding Party’s responses to Statement of Insurance.
23 ///
24 SPECIAL INTERROGATORY NO. 24:
25 Between January 1, 1995, and the present, was there in effect any policy of insurance
26 through which YOU were or might be insured in any manner (for example, primary, pro rata, or
27 excess liability coverage) for the DAMAGES, claims or actions alleged in this action? If so, for
28 each policy, state the name, address and telephone number of each named insured.
BREMER WHYTE BROWN &
11
O’MEARA LLP
20320 S.W. BIRCH STREET
(INSERT COMPANY NAME) RESPONSES TO CASE MANAGEMENT ORDER RE:
SECOND FLOOR INTERROGATORIES
NEWPORT BCH, CA 92660
(949) 221-1000
1 ///
2 RESPONSE TO SPECIAL INTERROGATORY NO. 24:
3 See Responding Party’s responses to Statement of Insurance.
4 ///
5 SPECIAL INTERROGATORY NO. 25:
6 Between January 1, 1995, and the present, was there in effect any policy of insurance
7 through which YOU were or might be insured in any manner (for example, primary, pro rata or
8 excess liability coverage) for the DAMAGES, claims or actions alleged in this action? If so, for
9 each policy, state the policy number.
10 ///
11 RESPONSE TO SPECIAL INTERROGATORY NO. 25:
12 See Responding Party’s responses to Statement of Insurance.
13 ///
14 SPECIAL INTERROGATORY NO. 26:
15 Between January 1, 1995, and the present, was there in effect any policy of insurance
16 through which YOU were or might be insured in any manner (for example, primary, pro rata, or
17 excess liability coverage) for the DAMAGES, claims or actions alleged in this action? If so, for
18 each policy, state the nature and limits of coverage for each type of coverage contained in the
19 policy.
20 ///
21 RESPONSE TO SPECIAL INTERROGATORY NO. 26:
22 See Responding Party’s responses to Statement of Insurance.
23 ///
24 SPECIAL INTERROGATORY NO. 27:
25 Between January 1, 1995, and the present, was there in effect any policy of insurance
26 through which YOU were or might be insured in any manner (for example, primary, pro rata or
27 excess liability coverage) for the DAMAGES, claims or actions alleged in this action? If so, for
28 each policy, state whether that insurance carrier is disputing the agreements' coverage of any
BREMER WHYTE BROWN &
12
O’MEARA LLP
20320 S.W. BIRCH STREET
(INSERT COMPANY NAME) RESPONSES TO CASE MANAGEMENT ORDER RE:
SECOND FLOOR INTERROGATORIES
NEWPORT BCH, CA 92660
(949) 221-1000
1 DAMAGES, claims or defenses alleged in this action. If so, state the DAMAGES, claims or
2 defenses so disputed. A copy of any reservation of rights letter shall be deposited in the Document
3 Depository.
4 ///
5 RESPONSE TO SPECIAL INTERROGATORY NO. 27:
6 (THIS INFORMATION MAY VARY BY PROJECT ) Discovery and investigation are
7 continuing. Responding Party reserves the right to supplement this response.
8 ///
9 SPECIAL INTERROGATORY NO. 28:
10 Do YOU have any policy of insurance issued between January 1, 1995, and the present
11 which names LEAVE BLANK as an additional insured? A copy of each declaration
12 page, certificate of insurance and additional insured endorsement shall be deposited in the
13 Document Depository.
14 ///
15 RESPONSE TO SPECIAL INTERROGATORY NO. 28:
16 (THIS INFORMATION MAY VARY BY PROJECT – IF ALWAYS THE SAME
17 ENTER YOUR RESPONSE HERE)
18 ///
19 SPECIAL INTERROGATORY NO. 29:
20 Do YOU have any policy of insurance issued between January 1, 1995, and the present
21 which names LEAVE BLANK as an additional insured? A copy of each declaration page,
22 certificate of insurance and additional insured endorsement shall be deposited in the Document
23 Depository
24 ///
25 RESPONSE TO SPECIAL INTERROGATORY NO. 29
26 (THIS INFORMATION MAY VARY BY PROJECT – IF ALWAYS THE SAME
27 ENTER YOUR RESPONSE HERE)
28 ///
BREMER WHYTE BROWN &
13
O’MEARA LLP
20320 S.W. BIRCH STREET
(INSERT COMPANY NAME) RESPONSES TO CASE MANAGEMENT ORDER RE:
SECOND FLOOR INTERROGATORIES
NEWPORT BCH, CA 92660
(949) 221-1000
1 ///
2 SPECIAL INTERROGATORY NO. 30:
3 Do YOU contend YOU have complied with all insurance provisions of YOUR subcontract
4 for SERVICES done by YOU at the PROJECT?
5 ///
6 RESPONSE TO SPECIAL INTERROGATORY NO. 30:
7 YES
8 ///
9 SPECIAL INTERROGATORY NO. 31:
10 Have any payments been made under the insurance policies listed in response to
11 Interrogatory No. 22 above that have been charged against the limitations of liability specified in
12 the policy? If so, state the policy and the amount and date of each payment.
13 ///
14 RESPONSE TO SPECIAL INTERROGATORY NO. 31:
15 (THIS INFORMATION MAY VARY)
16 ///
17 SPECIAL INTERROGATORY NO. 32:
18 Are YOU self-insured under any statute for the DAMAGES, claims or actions alleged in
19 this action? If so, specify the statute.
20 ///
21 RESPONSE TO SPECIAL INTERROGATORY NO. 32:
22 (INSERT YOUR RESPONSES FOR EACH OF THE QUESTIONS ABOVE OR ENTER
23 “NOT APPLICABLE”)
24 ///
25 ///
26 Dated
27
28
BREMER WHYTE BROWN &
14
O’MEARA LLP
20320 S.W. BIRCH STREET
(INSERT COMPANY NAME) RESPONSES TO CASE MANAGEMENT ORDER RE:
SECOND FLOOR INTERROGATORIES
NEWPORT BCH, CA 92660
(949) 221-1000
1
2
3
Attorneys for Cross-Defendant/Cross-Complainant,
4 (INSERT NAME OF COMPANY)
5
6
7
8
9
10 SUPERIOR COURT OF THE STATE OF CALIFORNIA
11 COUNTY OF SACRAMENTO
12
13 ) Case No.
Plaintiffs, )
14 )
v. ) (INSERT NAME OF COMPANY)'S
15 ) RESPONSES TO CASE MANAGEMENT
) ORDER RE: STATEMENT OF
16 Defendants. ) INSURANCE,
)
17 ) Complaint Filed:
(INSERT NAME OF COMPANY) )
18 Cross-Complainant, )
)
19 v. )
)
20 Cross-Defendants. )
)
21 )
)
22 )
)
23 )
)
24 )
)
25 PROPOUNDING PARTY: CASE MANAGEMENT ORDER
26 RESPONDING PARTY: (INSERT NAME OF COMPANY)
27 SET NO.: ONE
28
BREMER WHYTE BROWN &
15
O’MEARA LLP
20320 S.W. BIRCH STREET
(INSERT COMPANY NAME) RESPONSES TO CASE MANAGEMENT ORDER RE:
SECOND FLOOR INTERROGATORIES
NEWPORT BCH, CA 92660
(949) 221-1000
1 ///
2 ///
3 PRELIMINARY STATEMENT
4 These responses are made solely for the purpose, and in relation to this action. Each
5 response is given subject to appropriate objections (including but not limited to objections
6 concerning competency, relevancy, materiality, propriety, and admissibility) which would require
7 the exclusion of any statement contained herein if the interrogatory were asked of or any statement
8 contained herein were made by, a witness present and testifying in a court. All such objections and
9 grounds therefore are reserved and may be interposed at the time of trial.
10 This Responding Party has not completed its investigation of the facts relating to this
11 action, has not yet completed discovery in this action, and has not yet completed preparation for
12 trial. The following answers are therefore given without prejudice to this party's right to allege
13 and/or produce evidence of any subsequently discovered facts or circumstances.
14 All responses must be construed as given on the basis of recollection, discovery is not yet
15 complete and all responses are based solely upon such information presently available and
16 specifically known to the defendant. It is anticipated that further discovery, investigation, and
17 analysis will supply additional facts, add meaning to known facts, as well as establish entirely new
18 factual conclusions and legal contentions, all of which may necessitate substantial additions,
19 changes, or variations to the responses hereinafter set forth.
20 Except for facts explicitly admitted herein, no admission of any nature is to be implied or
21 inferred. The fact that any special interrogatory herein has been answered should not be taken as
22 an admission, or confession of the existence of any facts set forth or assumed by such special
23 interrogatory or that such response constitutes evidence of any fact thus set forth or assumed. All
24 responses must be construed as given on the basis of recollection.
25 These preliminary comments shall apply to each and every response given herein, and shall
26 be incorporated by reference as though fully set forth in all of the responses appearing in the
27 following pages.
28 ///
BREMER WHYTE BROWN &
16
O’MEARA LLP
20320 S.W. BIRCH STREET
(INSERT COMPANY NAME) RESPONSES TO CASE MANAGEMENT ORDER RE:
SECOND FLOOR INTERROGATORIES
NEWPORT BCH, CA 92660
(949) 221-1000
1
///
2
///
3 Cross-Defendant/Cross-Complainant,(INSERT NAME OF COMPANY), ("Responding Party")
hereby responds to Case Management Order Insurance Questionnaire as follows:
4 ///
5 RESPONSE TO INSURANCE QUESTIONNAIRE
6 QUESTION NO. 1:
7 Policy Number.
8 ///
9 RESPONSE TO QUESTION NO. 1:
10 (FOR EACH POLICY INSERT CARRIER NAME AND POLICY #)
11 (1) CARRIER NAME , Policy No. __________________
12 (2) CARRIER NAME , Policy No. __________________
13 (3) CARRIER NAME , Policy No. __________________
14 ///
15 QUESTION NO. 2:
16 The name and address of insurance carrier and adjuster assigned to the claim with effective
17 policy dates of each carrier.
18 ///
19 RESPONSE TO QUESTION NO. 2:
20 (ENTER CARRIER NAME, ADDRESS, AND POLICY DATES – CLAIMS
21 ADJUSTER WILL VARY)
22 (1)
23 (2)
24 (3)
25 ///
26 QUESTION NO. 3:
27 Type of policy (e.g. comprehensive general liability, professional liability, first party
28 property, occurrence and/or claims made).
BREMER WHYTE BROWN &
17
O’MEARA LLP
20320 S.W. BIRCH STREET
(INSERT COMPANY NAME) RESPONSES TO CASE MANAGEMENT ORDER RE:
SECOND FLOOR INTERROGATORIES
NEWPORT BCH, CA 92660
(949) 221-1000
1 RESPONSE TO QUESTION NO. 3:
2 (IDENTIFY TYPE OF POLICY FOR EACH POLICY IN QUESTION NO. 1)
3 ///
4 ///
5 QUESTION NO. 4:
6 Whether policy provided operations, completed operations and/or Broad Form Property
7 Damage coverage.
8 ///
9 RESPONSE TO QUESTION NO. 4:
10 (IDENTIFY FOR EACH POLICY IN QUESTION NO. 1)
11 ///
12 QUESTION NO. 5:
13 Whether there is a deductible or self-insured retention, and, if so, any per occurrence, per
14 claim or aggregate amount.
15 ///
16 RESPONSE TO QUESTION NO. 5:
17 (IDENTIFY FOR EACH POLICY IN QUESTION NO. 1)
18 ///
19 QUESTION NO. 6:
20 Original per occurrence and aggregate policy limits.
21 ///
22 RESPONSE TO QUESTION NO. 6:
23 (IDENTIFY FOR EACH POLICY IN QUESTION NO. 1)
24 ///
25 QUESTION NO. 7:
26 Remaining proceeds available on each insurance policy.
27 ///
28 ///
BREMER WHYTE BROWN &
18
O’MEARA LLP
20320 S.W. BIRCH STREET
(INSERT COMPANY NAME) RESPONSES TO CASE MANAGEMENT ORDER RE:
SECOND FLOOR INTERROGATORIES
NEWPORT BCH, CA 92660
(949) 221-1000
1 ///
2 ///
3 RESPONSE TO QUESTION NO. 7:
4 Objection, this request seeks information not calculated to lead to the discovery of
5 admissible evidence. Investigation and discovery are continuing. Responding party reserves the
6
right to supplement and/or amend this response at a later date. Discovery is continuing.
7
///
8
QUESTION NO. 8:
9
Identity of all relevant named insureds.
10
///
11
///
12
///
13
RESPONSE TO QUESTION NO. 8:
14
(ENTER COMPANY NAME AND ADDRESS).
15
///
16
QUESTION NO. 9:
17
Identity of all relevant additional insureds.
18
///
19
RESPONSE TO QUESTION NO. 9:
20
(THIS INFORMATION MAY VARY)
21
Investigation and discovery are continuing. Responding party reserves the right to supplement
22
and/or amend this response at a later date. Discovery is continuing.
23
///
24
QUESTION NO. 10:
25
The date(s) any tender was made, the identity to whom tender was made, and by whom.
26
///
27
RESPONSE TO QUESTION NO. 10:
28
BREMER WHYTE BROWN &
19
O’MEARA LLP
20320 S.W. BIRCH STREET
(INSERT COMPANY NAME) RESPONSES TO CASE MANAGEMENT ORDER RE:
SECOND FLOOR INTERROGATORIES
NEWPORT BCH, CA 92660
(949) 221-1000
1 (THIS INFORMATION MAY VARY)
2 Investigation and discovery are continuing. Responding party reserves the right to supplement
3 and/or amend this response at a later date. Discovery is continuing.
4 QUESTION NO. 11:
5 Whether the carrier has accepted or declined coverage and, if accepted, whether it did so
6 under a reservation of rights.
7 ///
8 RESPONSE TO QUESTION NO. 11:
9 (THIS INFORMATION MAY VARY)
10 Investigation and discovery are continuing. Responding party reserves the right to
11 supplement and/or amend this response at a later date. Discovery is continuing.
12 ///
13 QUESTION NO. 12:
14 The name, address and telephone number of the custodian of the policy.
15 ///
16 RESPONSE TO QUESTION NO. 12:
17 (ENTER COMPANY NAME AND ADDRESS – OR ALTERNATE
18 NAME/ADDRESS IF POLICY RECORDS ARE NOT MAINTAINED AT YOUR PLACE
19 OF BUSINESS)
20 ///
21 ///
22 Dated:
23 By:
Attorneys for Cross-Defendant/Cross-
24 Complainant,
(INSERT NAME OF COMPANY)
25
26
27
28
BREMER WHYTE BROWN &
20
O’MEARA LLP
20320 S.W. BIRCH STREET
(INSERT COMPANY NAME) RESPONSES TO CASE MANAGEMENT ORDER RE:
SECOND FLOOR INTERROGATORIES
NEWPORT BCH, CA 92660
(949) 221-1000
