David A. Green
Attorneys’ Business Address
City, ST ZIP Code
Phone | Fax
Plaintiff in pro per
in the superior court of california
for the county of san bernardino
| david a. green,Plaintiff,vs.westrux international inc.,Defendant | Case No.: CIVSB2200159PLAINTIFF’S RESPONSE TO DEFENDANT’S FORM INTERROGATORIES – GENERAL, SET ONE |
NOW COMES Plaintiff David A. Green, and hereby files this Response to Defendant’s Form Interrogatories – General, Set One, propounded upon him by Plaintiff, and hereby avers as follows:
RESPONSE TO INTERROGATORY NO. 1: No one helped Plaintiff prepare these responses to interrogatories.
RESPONSE TO INTERROGATORY NO. 2.1: Plaintiff’s name is David Green and he resides in the State of California.
RESPONSE TO INTERROGATORY NO. 2.2: Plaintiff was born on 12/06/1957 in Mt. Kisco, NY.
RESPONSE TO INTERROGATORY NO. 2.3: At the time of the accident, Plaintiff had a Class A driving license issued in the State of California with no restrictions.
RESPONSE TO INTERROGATORY NO. 2.4: At the time of the accident, Plaintiff did not have any other permit or license for the operation of a motor vehicle.
RESPONSE TO INTERROGATORY NO. 2.5: Plaintiff lives at 8533 Glendora Ave., CA 92344.
RESPONSE TO INTERROGATORY NO. 2.6: Since 2016, Plaintiff has been the Operations Manager at Excalbur Development Co. located at 8533 Glendora Ave., CA 92344.
RESPONSE TO INTERROGATORY NO. 2.7: Plaintiff avers that this interrogatory is moot and irrelevant.
RESPONSE TO INTERROGATORY NO. 2.8: Plaintiff has never been convicted of a felony.
RESPONSE TO INTERROGATORY NO. 2.9: Plaintiff can speak English with ease.
RESPONSE TO INTERROGATORY NO. 2.10: Plaintiff can read and write English with ease.
RESPONSE TO INTERROGATORY NO. 2.11: At the time of the accident, Plaintiff was not acting as an agent or employee of any person.
RESPONSE TO INTERROGATORY NO. 2.12: Neither Plaintiff nor any other person had any physical, emotional, or mental disability or condition that may have contributed to the occurrence of the incident.
RESPONSE TO INTERROGATORY NO. 2.13: Neither Plaintiff nor any other person took an alcoholic beverage, marijuana, or other drug or medication.
RESPONSE TO INTERROGATORY NO. 4.1: There was no policy of insurance in effect at the time of the accident.
RESPONSE TO INTERROGATORY NO. 4.2: Plaintiff is not self-insured under any statute.
RESPONSE TO INTERROGATORY NO. 7.1: Plaintiff does not attribute any loss or damage to a vehicle or other property to the incident.
RESPONSE TO INTERROGATORY NO. 7.2:
RESPONSE TO INTERROGATORY NO. 7.3: Not applicable.
RESPONSE TO INTERROGATORY NO. 8.1: Plaintiff attributes loss of income or earning capacity to the incident.
RESPONSE TO INTERROGATORY NO. 8.2: Please see Response to Interrogatory No. 2.6.
RESPONSE TO INTERROGATORY NO. 8.3: Plaintiff last worked for compensation on 06/01/2020,
RESPONSE TO INTERROGATORY NO. 8.4: Plaintiff’s monthly income at the time of the incident was $4,000.
RESPONSE TO INTERROGATORY NO. 8.5: Plaintiff has not been able to return to work after the incident.
RESPONSE TO INTERROGATORY NO. 8.6:
RESPONSE TO INTERROGATORY NO. 8.7: Plaintiff has been losing more than $2,000 per month, totaling $24,000 per year.
RESPONSE TO INTERROGATORY NO. 8.8: Plaintiff will lose income in the future as a result of the incident as he does not have a truck to work with.
RESPONSE TO INTERROGATORY NO. 9.1: Plaintiff has lost the reputation of his business as he is unable to meet customers’ supply demands.
RESPONSE TO INTERROGATORY NO. 9.2: These documents are in the custody of Defendant.
RESPONSE TO INTERROGATORY NO. 11.1: Plaintiff has never filed a personal injury lawsuit before.
RESPONSE TO INTERROGATORY NO. 11.2: Plaintiff has never made a written claim or demand for workers’ compensation benefits.
RESPONSE TO INTERROGATORY NO. 12.1: Plaintiff does not have sufficient information to respond to this interrogatory.
RESPONSE TO INTERROGATORY NO. 12.2: No one has interviewed Plaintiff or his legal representative regarding the incident.
RESPONSE TO INTERROGATORY NO. 12.3: No one has obtained a written or recorded statement from any individual regarding the incident.
RESPONSE TO INTERROGATORY NO. 12.4: Neither Plaintiff nor anyone acting on his behalf knows of any photographs, films, or videotapes depicting any place, object or individual concerning the incident or Plaintiff’s injuries.
RESPONSE TO INTERROGATORY NO. 12.5: Neither Plaintiff nor anyone acting on his behalf knows of any diagram, reproduction, or model of any place or thing concerning the incident.
RESPONSE TO INTERROGATORY NO. 12.6: No report was made concerning the incident.
RESPONSE TO INTERROGATORY NO. 12.7: Neither Plaintiff nor anyone acting on his behalf inspected the scene of the incident.
RESPONSE TO INTERROGATORY NO. 13.1: Neither Plaintiff nor anyone acting on his behalf conducted surveillance of any individual involved in the incident or party to this suit.
RESPONSE TO INTERROGATORY NO. 13.2: Not applicable.
RESPONSE TO INTERROGATORY NO. 14.1: Neither Plaintiff nor anyone acting on his behalf contends that any person involved in the incident violated any statute, ordinance or regulation.
RESPONSE TO INTERROGATORY NO. 14.2: No one was charged with violation of any law.
Dated this ____ day of May, 2022.
Respectfully Submitted,
___________________________________
David A. Green
Plaintiff in pro per
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