Interrogatories: Plaintiffs in LA had to answer these questions in civil cases against the Catholic Church

*****
By Kay Ebeling

Attorneys for Cardinal Roger Mahony and the LA Archdiocese sent these interrogatories to plaintiffs in the Clergy Cases which were settled in July 2007.

After each interrogatory is a code:

-Provided Answer
-Responded with objection only
-Court ruled no response necessary

PER lead plaintiff firm Kiesel, Boucher and Larson who provided the document to city of angels blog: Where the court ruled "no response necessary", it probably means we had refused to answer, they brought a Motion to Compel and we prevailed. There also may be others in the mix that we had fought not to answer, but the court ruled against us. Where we responded "with objection only" it may mean this was an ongoing fight, there may not have been a Motion to Compel yet.

Interrogatories: n. pl. Formal or written questions, as to a witness, usually requiring an answer under oath (Further definition in column at left.)

INTERROGATORY NO. 1:
Have you ever been convicted of any crime? PROVIDED ANSWER
INTERROGATORY NO. 2:
If you have been convicted of a crime or crimes, please state each city and state where you were convicted. PROVIDED ANSWER
INTERROGATORY NO. 3:
If you have been convicted of a crime or crimes, please state the date of each conviction. PROVIDED ANSWER
INTERROGATORY NO. 4:
If you have been convicted of a crime or crimes, please state each offense. PROVIDED ANSWER
INTERROGATORY NO. 5:
If you have been convicted of a crime or crimes, please state the court and case number of each conviction. PROVIDED ANSWER
INTERROGATORY NO. 6:
State the names of each of your siblings. PROVIDED ANSWER
INTERROGATORY NO. 7:
State the ages of each of your siblings. PROVIDED ANSWER
INTERROGATORY NO. 8:
State the last known addresses or whereabouts of each of your siblings. PROVIDED ANSWER
INTERROGATORY NO. 9:
State the names of each of your parents, foster parents, and/or other legal guardians while a minor. PROVIDED ANSWER
INTERROGATORY NO. 10:
State the ages of each of your parents, foster parents, and/or other legal guardians while a minor. PROVIDED ANSWER
INTERROGATORY NO. 11:
State the last known addresses or whereabouts of each of your parents, foster parents, and/or other legal guardians while a minor. PROVIDED ANSWER
INTERROGATORY NO. 12:
State the names of each of your children. PROVIDED ANSWER
INTERROGATORY NO. 13:
State the ages of each of your children. PROVIDED ANSWER
INTERROGATORY NO. 14:
State the last known addresses or whereabouts of each of your children. PROVIDED ANSWER
INTERROGATORY NO. 15:
State the names of all of your former spouses. PROVIDED ANSWER
INTERROGATORY NO. 16:
State the ages of all of your former spouses. PROVIDED ANSWER
INTERROGATORY NO. 17:
State the last known addresses or whereabouts of all of your former spouses. PROVIDED ANSWER
INTERROGATORY NO. 18:
State the name of each school or other academic or vocational institution you have attended, beginning with pre-school. PROVIDED ANSWER
INTERROGATORY NO. 19:
State the address of each school or other academic or vocational institution you have attended, beginning with pre-school. PROVIDED ANSWER
INTERROGATORY NO. 20:
State the dates you attended each school or other academic or vocational institution you have attended, beginning with pre-school. PROVIDED ANSWER
INTERROGATORY NO. 21:
State the highest grade level you have completed. PROVIDED ANSWER
INTERROGATORY NO. 22:
State the degrees you have received. PROVIDED ANSWER
INTERROGATORY NO. 23:
State the name of your present employer or place of self-employment. PROVIDED ANSWER
INTERROGATORY NO. 24:
State the address of your present employer or place of self-employment. PROVIDED ANSWER
INTERROGATORY NO. 25:
State the telephone number of your present employer or place of self-employment. PROVIDED ANSWER
INTERROGATORY NO. 26:
State the name of your past employers or places of self-employment. PROVIDED ANSWER
INTERROGATORY NO. 27:
State the address of your past employers or places of self-employment. PROVIDED ANSWER
INTERROGATORY NO. 28:
State the telephone number of your past employers or places of self-employment. PROVIDED ANSWER
INTERROGATORY NO. 29:
For all employers or places of self-employment at which you have worked, please state the dates you worked at each. PROVIDED ANSWER
INTERROGATORY NO. 30:
For all employers or places of self-employment at which you have worked, please state the nature of your work at each. PROVIDED ANSWER
INTERROGATORY NO. 31:
For all employers or places of self-employment at which you have worked, please state your job title for each. PROVIDED ANSWER
INTERROGATORY NO. 32:
For all employers or places of self-employment at which you have worked, please state the name of your immediate supervisor at each. PROVIDED ANSWER
INTERROGATORY NO. 33:
For each ACCUSED PERSON, please state on what basis you allege the ACCUSED PERSON was an employee, agent, volunteer or representative of any defendant in this lawsuit. COURT RULED NO RESPONSE NECESSARY
INTERROGATORY NO. 34:
For all HEALTH CARE PROVIDERS who have provided you with consultation, examination, therapy or other treatment during your lifetime, please state the HEALTH CARE PROVIDER's name. PROVIDED ANSWER
INTERROGATORY NO. 35:
For all HEALTH CARE PROVIDERS who have provided you with consultation, examination, therapy or other treatment during your lifetime, please state the HEALTH CARE PROVIDER's address. PROVIDED ANSWER
INTERROGATORY NO. 36:
For all HEALTH CARE PROVIDERS who have provided you with consultation, examination, therapy or other treatment during your lifetime, please state the HEALTH CARE PROVIDER's telephone number. PROVIDED ANSWER
INTERROGATORY NO. 37:
For all HEALTH CARE PROVIDERS who have provided you with consultation, examination, therapy or other treatment during your lifetime, please state the type of consultation, examination, or treatment provided. PROVIDED ANSWER
INTERROGATORY NO. 38:
For all HEALTH CARE PROVIDERS who have provided you with consultation, examination, therapy or other treatment during your lifetime, please state the dates you received consultation, examination, or treatment. PROVIDED ANSWER
INTERROGATORY NO. 39:
For each HEALTH CARE PROVIDER from whom you received any consultation or examination or treatment for any physical injury you attribute to the sexual abuse you have alleged in this case, please state the name. PROVIDED ANSWER
INTERROGATORY NO. 40:
For each HEALTH CARE PROVIDER from whom you received any consultation or examination or treatment for any physical injury you attribute to the sexual abuse you have alleged in this case, please state the address. PROVIDED ANSWER
INTERROGATORY NO. 41:
For each HEALTH CARE PROVIDER from whom you received any consultation or examination or treatment for any physical injury you attribute to the sexual abuse you have alleged in this case, please state the telephone number. PROVIDED ANSWER
INTERROGATORY NO. 42:
For each HEALTH CARE PROVIDER from whom you received any consultation or examination or treatment for any physical injury you attribute to the sexual abuse you have alleged in this case, please state the charges to date. PROVIDED ANSWER
INTERROGATORY NO. 43:
Has any HEALTH CARE PROVIDER advised that you may require future or additional treatment for any physical injury that you attribute to the sexual abuse you have alleged in this case? PROVIDED ANSWER
INTERROGATORY NO. 44:
For each instance in which a HEALTH CARE PROVIDER advised that you may require future or additional treatment for any physical injury that you attribute to the sexual abuse you have alleged in this case, please state the name of each HEALTH CARE PROVIDER. PROVIDED ANSWER
INTERROGATORY NO. 45:
For each instance in which a HEALTH CARE PROVIDER advised that you may require future or additional treatment for any physical injury that you attribute to the sexual abuse you have alleged in this case, please state the address of each HEALTH CARE PROVIDER. PROVIDED ANSWER
INTERROGATORY NO. 46:
For each instance in which a HEALTH CARE PROVIDER advised that you may require future or additional treatment for any physical injury that you attribute to the sexual abuse you have alleged in this case, please state the complaints for which the treatment was advised. PROVIDED ANSWER
INTERROGATORY NO. 47:
For each instance in which a HEALTH CARE PROVIDER advised that you may require future or additional treatment for any physical injury that you attribute to the sexual abuse you have alleged in this case, please state the nature of the treatment. PROVIDED ANSWER
INTERROGATORY NO. 48:
For each instance in which a HEALTH CARE PROVIDER advised that you may require future or additional treatment for any physical injury that you attribute to the sexual abuse you have alleged in this case, please state the duration of the treatment. PROVIDED ANSWER
INTERROGATORY NO. 49:
For each instance in which a HEALTH CARE PROVIDER advised that you may require future or additional treatment for any physical injury that you attribute to the sexual abuse you have alleged in this case, please state the estimated cost of the treatment. PROVIDED ANSWER
INTERROGATORY NO. 50:
For each HEALTH CARE PROVIDER from whom you received any consultation or examination or treatment for any psychological injury or illness you attribute to the sexual abuse you have alleged in this case, please state the name. PROVIDED ANSWER
INTERROGATORY NO. 51:
For each HEALTH CARE PROVIDER from whom you received any consultation or examination or treatment for any psychological injury or illness you attribute to the sexual abuse you have alleged in this case, please state the address. PROVIDED ANSWER
INTERROGATORY NO. 52:
For each HEALTH CARE PROVIDER from whom you received any consultation or examination or treatment for any psychological injury or illness you attribute to the sexual abuse you have alleged in this case, please state the telephone number. PROVIDED ANSWER
INTERROGATORY NO. 53:
For each HEALTH CARE PROVIDER from whom you received any consultation or examination or treatment for any psychological injury or illness you attribute to the sexual abuse you have alleged in this case, please state the charges to date. PROVIDED ANSWER
INTERROGATORY NO. 54:
Has any HEALTH CARE PROVIDER advised that you may require future or additional treatment for any psychological injury that you attribute to the sexual abuse you have alleged in this case? PROVIDED ANSWER
INTERROGATORY NO. 55:
For each instance in which a HEALTH CARE PROVIDER advised that you may require future or additional treatment for any psychological injury that you attribute to the sexual abuse you have alleged in this case, please state the name of each HEALTH CARE PROVIDER. PROVIDED ANSWER
INTERROGATORY NO. 56:
For each instance in which a HEALTH CARE PROVIDER advised that you may require future or additional treatment for any psychological injury that you attribute to the sexual abuse you have alleged in this case, please state the address of each HEALTH CARE PROVIDER. PROVIDED ANSWER
INTERROGATORY NO. 57:
For each instance in which a HEALTH CARE PROVIDER advised that you may require future or additional treatment for any psychological injury that you attribute to the sexual abuse you have alleged in this case, please state the complaints for which the treatment was advised. PROVIDED ANSWER
INTERROGATORY NO. 58:
For each instance in which a HEALTH CARE PROVIDER advised that you may require future or additional treatment for any psychological injury that you attribute to the sexual abuse you have alleged in this case, please state the nature of the treatment. PROVIDED ANSWER
INTERROGATORY NO. 59:
For each instance in which a HEALTH CARE PROVIDER advised that you may require future or additional treatment for any psychological injury that you attribute to the sexual abuse you have alleged in this case, please state the duration of the treatment. PROVIDED ANSWER
INTERROGATORY NO. 60:
For each instance in which a HEALTH CARE PROVIDER advised that you may require future or additional treatment for any psychological injury that you attribute to the sexual abuse you have alleged in this case, please state the estimated cost of the treatment. PROVIDED ANSWER
INTERROGATORY NO. 61:
Do you attribute any loss of income or earning capacity to the sexual abuse you have alleged in this case? PROVIDED ANSWER
INTERROGATORY NO. 62:
State the dates you did not work and for which you lost income, as a result of the sexual abuse you have alleged in this case. PROVIDED ANSWER
INTERROGATORY NO. 63:
State the total income you have lost to date as a result of the sexual abuse you have alleged in this case. PROVIDED ANSWER
INTERROGATORY NO. 64:
State how you calculated the total income you have lost to date as a result of the sexual abuse you have alleged in this case. PROVIDED ANSWER
INTERROGATORY NO. 65:
Will you lose income in the future as a result of the sexual abuse you have alleged in this case? PROVIDED ANSWER
INTERROGATORY NO. 66:
If you will lose income in the future as a result of the sexual abuse you have alleged in this case, please state the facts upon which you base this contention. PROVIDED ANSWER
INTERROGATORY NO. 67:
If you will lose income in the future as a result of the sexual abuse you have alleged in this case, please state an estimate of the amount. PROVIDED ANSWER
INTERROGATORY NO. 68:
If you will lose income in the future as a result of the sexual abuse you have alleged in this case, please state an estimate of how long you will be unable to work. PROVIDED ANSWER
INTERROGATORY NO. 69:
If you will lose income in the future as a result of the sexual abuse you have alleged in this case, please state how the claim for future income is calculated. PROVIDED ANSWER
INTERROGATORY NO. 70:
State your present residence address. PROVIDED ANSWER
INTERROGATORY NO. 71:
State each of your residence addresses during your life. PROVIDED ANSWER
INTERROGATORY NO. 72:
State your residence address for the time period in which the abuse is alleged to have occurred. PROVIDED ANSWER
INTERROGATORY NO. 73:
State the dates you lived at all your past residence addresses. PROVIDED ANSWER
INTERROGATORY NO. 74:
State your social security number. PROVIDED ANSWER
INTERROGATORY NO. 75:
Have you ever served in the military? PROVIDED ANSWER
INTERROGATORY NO. 76:
If you served in the military, please state your dates of service. PROVIDED ANSWER
INTERROGATORY NO. 77:
If you served in the military, please state where you served. PROVIDED ANSWER
INTERROGATORY NO. 78:
If you served in the military, please state the branch in which you served. PROVIDED ANSWER
INTERROGATORY NO. 79:
If you served in the military, please state the names of your immediate superior officers. PROVIDED ANSWER
INTERROGATORY NO. 80:
In what language and dialect do you normally speak? PROVIDED ANSWER
INTERROGATORY NO. 81:
In what language and dialect do you normally read and write? COURT RULED NO RESPONSE NECESSARY
INTERROGATORY NO. 82:
Within 24 hours of any act of sexual abuse you have alleged in this case did you or any person involved in the sexual abuse use or take any of the following substances: alcoholic beverage, marijuana, or other drug or medication of any kind (prescription or not)? COURT RULED NO RESPONSE NECESSARY
INTERROGATORY NO. 83:
If within 24 hours of any act of sexual abuse you have alleged in this case you or any person involved in the sexual abuse used or took an alcoholic beverage, marijuana, or other drug or medication of any kind (prescription or not), please state the name of the person or persons who took or used the substance. COURT RULED NO RESPONSE NECESSARY
INTERROGATORY NO. 84:
If within 24 hours of any act of sexual abuse you have alleged in this case you or any person involved in the sexual abuse used or took an alcoholic beverage, marijuana, or other drug or medication of any kind (prescription or not), please state the address of the person or persons who took or used the substance. COURT RULED NO RESPONSE NECESSARY
INTERROGATORY NO. 85:
If within 24 hours of any act of sexual abuse you have alleged in this case you or any person involved in the sexual abuse used or took an alcoholic beverage, marijuana, or other drug or medication of any kind (prescription or not), please state the telephone number of the person or persons who took or used the substance. COURT RULED NO RESPONSE NECESSARY
INTERROGATORY NO. 86:
If within 24 hours of any act of sexual abuse you have alleged in this case you or any person involved in the sexual abuse used or took an alcoholic beverage, marijuana, or other drug or medication of any kind (prescription or not), please state the nature of each substance. COURT RULED NO RESPONSE NECESSARY
INTERROGATORY NO. 87:
If within 24 hours of any act of sexual abuse you have alleged in this case you or any person involved in the sexual abuse used or took an alcoholic beverage, marijuana, or other drug or medication of any kind (prescription or not), please state the quantity of each substance used or taken. COURT RULED NO RESPONSE NECESSARY
INTERROGATORY NO. 88:
If within 24 hours of any act of sexual abuse you have alleged in this case you or any person involved in the sexual abuse used or took an alcoholic beverage, marijuana, or other drug or medication of any kind (prescription or not), please state the date and time of day when each substance was used or taken. COURT RULED NO RESPONSE NECESSARY
INTERROGATORY NO. 89:
If within 24 hours of any act of sexual abuse you have alleged in this case you or any person involved in the sexual abuse used or took an alcoholic beverage, marijuana, or other drug or medication of any kind (prescription or not), please state the address where each substance was used or taken. COURT RULED NO RESPONSE NECESSARY
INTERROGATORY NO. 90:
If within 24 hours of any act of sexual abuse you have alleged in this case you or any person involved in the sexual abuse used or took an alcoholic beverage, marijuana, or other drug or medication of any kind (prescription or not), please state the name of each person who was present when each substance was used or taken. COURT RULED NO RESPONSE NECESSARY
INTERROGATORY NO. 91:
If within 24 hours of any act of sexual abuse you have alleged in this case you or any person involved in the sexual abuse used or took an alcoholic beverage, marijuana, or other drug or medication of any kind (prescription or not), please state the address of each person who was present when each substance was used or taken. COURT RULED NO RESPONSE NECESSARY
INTERROGATORY NO. 92:
If within 24 hours of any act of sexual abuse you have alleged in this case you or any person involved in the sexual abuse used or took an alcoholic beverage, marijuana, or other drug or medication of any kind (prescription or not), please state the telephone number of each person who was present when each substance was used or taken. COURT RULED NO RESPONSE NECESSARY
INTERROGATORY NO. 93:
If within 24 hours of any act of sexual abuse you have alleged in this case you or any person involved in the sexual abuse used or took an alcoholic beverage, marijuana, or other drug or medication of any kind (prescription or not), please state the name of any person that prescribed or furnished the substance. COURT RULED NO RESPONSE NECESSARY
INTERROGATORY NO. 94:
If within 24 hours of any act of sexual abuse you have alleged in this case you or any person involved in the sexual abuse used or took an alcoholic beverage, marijuana, or other drug or medication of any kind (prescription or not), please state the address of any person that prescribed or furnished the substance. COURT RULED NO RESPONSE NECESSARY
INTERROGATORY NO. 95:
If within 24 hours of any act of sexual abuse you have alleged in this case you or any person involved in the sexual abuse used or took an alcoholic beverage, marijuana, or other drug or medication of any kind (prescription or not), please state the telephone number of any person that prescribed or furnished the substance. COURT RULED NO RESPONSE NECESSARY
INTERROGATORY NO. 96:
If within 24 hours of any act of sexual abuse you have alleged in this case you or any person involved in the sexual abuse used or took an alcoholic beverage, marijuana, or other drug or medication of any kind (prescription or not), please state the condition for which it was prescribed or furnished. COURT RULED NO RESPONSE NECESSARY
INTERROGATORY NO. 97:
If within 24 hours of any act of sexual abuse you have alleged in this case you or any person involved in the sexual abuse used or took an alcoholic beverage, marijuana, or other drug or medication of any kind (prescription or not), please state the name of any person who provided each substance to any minor. COURT RULED NO RESPONSE NECESSARY
INTERROGATORY NO. 98:
If within 24 hours of any act of sexual abuse you have alleged in this case you or any person involved in the sexual abuse used or took an alcoholic beverage, marijuana, or other drug or medication of any kind (prescription or not), please state the address of any person who provided each substance to any minor. COURT RULED NO RESPONSE NECESSARY
INTERROGATORY NO. 99:
If within 24 hours of any act of sexual abuse you have alleged in this case you or any person involved in the sexual abuse used or took an alcoholic beverage, marijuana, or other drug or medication of any kind (prescription or not), please state the telephone number of any person who provided each substance to any minor. COURT RULED NO RESPONSE NECESSARY
INTERROGATORY NO. 100:
Have you taken any medication, prescribed or not, as a result of injuries that you attribute to the sexual abuse you have alleged in this case? PROVIDED ANSWER
INTERROGATORY NO. 101:
For each medication you have taken, whether prescribed or not as a result of injuries that you attribute to the sexual abuse you have alleged in this case, please state the name of the medication. PROVIDED ANSWER
INTERROGATORY NO. 102:
For each medication you have taken, whether prescribed or not as a result of injuries that you attribute to the sexual abuse you have alleged in this case, please state the name of the person who prescribed or furnished the medication. PROVIDED ANSWER
INTERROGATORY NO. 103:
For each medication you have taken, whether prescribed or not as a result of injuries that you attribute to the sexual abuse you have alleged in this case, please state the address of the person who prescribed or furnished the medication. PROVIDED ANSWER
INTERROGATORY NO. 104:
For each medication you have taken, whether prescribed or not as a result of injuries that you attribute to the sexual abuse you have alleged in this case, please state the date prescribed or furnished. PROVIDED ANSWER
INTERROGATORY NO. 105:
For each medication you have taken, whether prescribed or not as a result of injuries that you attribute to the sexual abuse you have alleged in this case, please state the dates you began taking the medication. PROVIDED ANSWER
INTERROGATORY NO. 106:
For each medication you have taken, whether prescribed or not as a result of injuries that you attribute to the sexual abuse you have alleged in this case, please state the dates you stopped taking the medication. PROVIDED ANSWER
INTERROGATORY NO. 107:
For each medication you have taken, whether prescribed or not as a result of injuries that you attribute to the sexual abuse you have alleged in this case, please state the cost to date. PROVIDED ANSWER
INTERROGATORY NO. 108:
List all physical, mental, and emotional disabilities you had immediately before the sexual abuse you have alleged in this case. PROVIDED ANSWER
INTERROGATORY NO. 109:
Except for this action, have you filed an action for compensation for any personal injuries? PROVIDED ANSWER
INTERROGATORY NO. 110:
Except for this action, have you made a written claim for compensation for your personal injuries? PROVIDED ANSWER
INTERROGATORY NO. 111:
For all past instances in which you have sought compensation for any personal injuries (not including this case), please state the date of the incident giving rise to the action, claim, or demand. PROVIDED ANSWER
INTERROGATORY NO. 112:
For all past instances in which you have sought compensation for any personal injuries (not including this case), please state the time of the incident giving rise to the action, claim, or demand. PROVIDED ANSWER
INTERROGATORY NO. 113:
For all past instances in which you have sought compensation for any personal injuries (not including this case), please state the location (closest street address or intersection) of the incident giving rise to the action, claim, or demand. PROVIDED ANSWER
INTERROGATORY NO. 114:
For all past instances in which you have sought compensation for any personal injuries (not including this case), please state the name of each person against whom the claim was made or action filed. PROVIDED ANSWER
INTERROGATORY NO. 115:
For all past instances in which you have sought compensation for any personal injuries (not including this case), please state the address of each person against whom the claim was made or action filed. PROVIDED ANSWER
INTERROGATORY NO. 116:
For all past instances in which you have sought compensation for any personal injuries (not including this case), please state the telephone number of each person against whom the claim was made or action filed. PROVIDED ANSWER
INTERROGATORY NO. 117:
For all past instances in which you have sought compensation for any personal injuries (not including this case), please state the court in which any action was filed. PROVIDED ANSWER
INTERROGATORY NO. 118:
For all past instances in which you have sought compensation for any personal injuries (not including this case), please state the names of the parties in any action filed. PROVIDED ANSWER
INTERROGATORY NO. 119:
For all past instances in which you have sought compensation for any personal injuries (not including this case), please state the case number in any action filed. PROVIDED ANSWER
INTERROGATORY NO. 120:
For all past instances in which you have sought compensation for any personal injuries (not including this case), please state the name of any attorney representing you. RESPONDED WITH OBJECTION ONLY
INTERROGATORY NO. 121:
For all past instances in which you have sought compensation for any personal injuries (not including this case), please state the address of any attorney representing you. RESPONDED WITH OBJECTION ONLY
INTERROGATORY NO. 122:
For all past instances in which you have sought compensation for any personal injuries (not including this case), please state the telephone number of any attorney representing you. RESPONDED WITH OBJECTION ONLY
INTERROGATORY NO. 123:
For all past instances in which you have sought compensation for any personal injuries (not including this case), please state whether the claim or action has been resolved or is pending. PROVIDED ANSWER
INTERROGATORY NO. 124:
For all past instances in which you have sought compensation for any personal injuries (not including this case), please state the nature of your personal injury. PROVIDED ANSWER
INTERROGATORY NO. 125:
For all past instances in which you have sought compensation for any personal injuries (not including this case), please state whether the action, claim or demand resulted from an act or acts of sexual abuse. PROVIDED ANSWER
INTERROGATORY NO. 126:
Have you ever made a written claim or demand for worker's compensation benefits? PROVIDED ANSWER
INTERROGATORY NO. 127:
For each instance in which you have made a written claim or demand for worker's compensation benefits, please state the date of the incident giving rise to the claim. PROVIDED ANSWER
INTERROGATORY NO. 128:
For each instance in which you have made a written claim or demand for worker's compensation benefits, please state the time of the incident giving rise to the claim. PROVIDED ANSWER
INTERROGATORY NO. 129:
For each instance in which you have made a written claim or demand for worker's compensation benefits, please state the place of the incident giving rise to the claim. PROVIDED ANSWER
INTERROGATORY NO. 130:
For each instance in which you have made a written claim or demand for worker's compensation benefits, please state the name of your employer at the time of the injury. PROVIDED ANSWER
INTERROGATORY NO. 131:
For each instance in which you have made a written claim or demand for worker's compensation benefits, please state the address of your employer at the time of the injury. PROVIDED ANSWER
INTERROGATORY NO. 132:
For each instance in which you have made a written claim or demand for worker's compensation benefits, please state the telephone number of your employer at the time of the injury. PROVIDED ANSWER
INTERROGATORY NO. 133:
For each instance in which you have made a written claim or demand for worker's compensation benefits, please state the name of the worker's compensation insurer. PROVIDED ANSWER
INTERROGATORY NO. 134:
For each instance in which you have made a written claim or demand for worker's compensation benefits, please state the address of the worker's compensation insurer. PROVIDED ANSWER
INTERROGATORY NO. 135:
For each instance in which you have made a written claim or demand for worker's compensation benefits, please state the telephone number of the worker's compensation insurer. PROVIDED ANSWER
INTERROGATORY NO. 136:
For each instance in which you have made a written claim or demand for worker's compensation benefits, please state the claim number. PROVIDED ANSWER
INTERROGATORY NO. 137:
For each instance in which you have made a written claim or demand for worker's compensation benefits, please state the period of time during which you received worker's compensation benefits. PROVIDED ANSWER
INTERROGATORY NO. 138:
For each instance in which you have made a written claim or demand for worker's compensation benefits, please state a description of the injury. PROVIDED ANSWER
INTERROGATORY NO. 139:
For each instance in which you have made a written claim or demand for worker's compensation benefits, please state the name of any HEALTH CARE PROVIDER that provided services. PROVIDED ANSWER
INTERROGATORY NO. 140:
For each instance in which you have made a written claim or demand for worker's compensation benefits, please state the address of any HEALTH CARE PROVIDER that provided services. PROVIDED ANSWER
INTERROGATORY NO. 141:
For each instance in which you have made a written claim or demand for worker's compensation benefits, please state the telephone number of any HEALTH CARE PROVIDER that provided services. PROVIDED ANSWER
INTERROGATORY NO. 142:
For each instance in which you have made a written claim or demand for worker's compensation benefits, please state the case number at the Worker's Compensation Appeals Board. PROVIDED ANSWER
INTERROGATORY NO. 143:
Have you or anyone acting on your behalf interviewed any individual concerning the sexual abuse you have alleged in this case? PROVIDED ANSWER
INTERROGATORY NO. 144:
For each individual whom you or anyone acting on your behalf interviewed concerning the sexual abuse you have alleged in this case, please state the name of the individual interviewed. PROVIDED ANSWER
INTERROGATORY NO. 145:
For each individual whom you or anyone acting on your behalf interviewed concerning the sexual abuse you have alleged in this case, please state the address of the individual interviewed. PROVIDED ANSWER
INTERROGATORY NO. 146:
For each individual whom you or anyone acting on your behalf interviewed concerning the sexual abuse you have alleged in this case, please state the telephone number of the individual interviewed. PROVIDED ANSWER
INTERROGATORY NO. 147:
For each individual whom you or anyone acting on your behalf interviewed concerning the sexual abuse you have alleged in this case, please state the date of the interview. PROVIDED ANSWER
INTERROGATORY NO. 148:
For each individual whom you or anyone acting on your behalf interviewed concerning the sexual abuse you have alleged in this case, please state the name of the person who conducted the interview. PROVIDED ANSWER
INTERROGATORY NO. 149:
For each individual whom you or anyone acting on your behalf interviewed concerning the sexual abuse you have alleged in this case, please state the address of the person who conducted the interview. PROVIDED ANSWER
INTERROGATORY NO. 150:
For each individual whom you or anyone acting on your behalf interviewed concerning the sexual abuse you have alleged in this case, please state the telephone number of the person who conducted the interview. PROVIDED ANSWER
INTERROGATORY NO. 151:
Have you or anyone acting on your behalf obtained a written or recorded statement from any individual concerning the sexual abuse you have alleged in this case? PROVIDED ANSWER
INTERROGATORY NO. 152:
For each instance in which you or anyone acting on your behalf obtained a written or recorded statement from any individual concerning the sexual abuse you have alleged in this case, please state the name of the individual from whom the statement was obtained. PROVIDED ANSWER
INTERROGATORY NO. 153:
For each instance in which you or anyone acting on your behalf obtained a written or recorded statement from any individual concerning the sexual abuse you have alleged in this case, please state the address of the individual from whom the statement was obtained. PROVIDED ANSWER
INTERROGATORY NO. 154:
For each instance in which you or anyone acting on your behalf obtained a written or recorded statement from any individual concerning the sexual abuse you have alleged in this case, please state the name of the individual who obtained the statement. PROVIDED ANSWER
INTERROGATORY NO. 155:
For each instance in which you or anyone acting on your behalf obtained a written or recorded statement from any individual concerning the sexual abuse you have alleged in this case, please state the address of the individual who obtained the statement. PROVIDED ANSWER
INTERROGATORY NO. 156:
For each instance in which you or anyone acting on your behalf obtained a written or recorded statement from any individual concerning the sexual abuse you have alleged in this case, please state the telephone number of the individual who obtained the statement. PROVIDED ANSWER
INTERROGATORY NO. 157:
For each instance in which you or anyone acting on your behalf obtained a written or recorded statement from any individual concerning the sexual abuse you have alleged in this case, please state the date the statement was obtained. PROVIDED ANSWER
INTERROGATORY NO. 158:
For each instance in which you or anyone acting on your behalf obtained a written or recorded statement from any individual concerning the sexual abuse you have alleged in this case, please state the name of each person who has the original statement or a copy. PROVIDED ANSWER
INTERROGATORY NO. 159:
For each instance in which you or anyone acting on your behalf obtained a written or recorded statement from any individual concerning the sexual abuse you have alleged in this case, please state the address of each person who has the original statement or a copy. PROVIDED ANSWER
INTERROGATORY NO. 160:
For each instance in which you or anyone acting on your behalf obtained a written or recorded statement from any individual concerning the sexual abuse you have alleged in this case, please state the telephone number of each person who has the original statement or a copy. PROVIDED ANSWER
INTERROGATORY NO. 161:
Was a report made by any person concerning the sexual abuse you have alleged in this case to any law enforcement agency, any child protective agency or any defendant? PROVIDED ANSWER
INTERROGATORY NO. 162:
For each instance in which a report was made by any person concerning the sexual abuse you have alleged in this case to any law enforcement agency, any child protective agency or any defendant, please state the name of the person who made the report. PROVIDED ANSWER
INTERROGATORY NO. 163:
For each instance in which a report was made by any person concerning the sexual abuse you have alleged in this case to any law enforcement agency, any child protective agency or any defendant, please state the title of the person who made the report. PROVIDED ANSWER
INTERROGATORY NO. 164:
For each instance in which a report was made by any person concerning the sexual abuse you have alleged in this case to any law enforcement agency, any child protective agency or any defendant, please state the identification number of the person who made the report. PROVIDED ANSWER
INTERROGATORY NO. 165:
For each instance in which a report was made by any person concerning the sexual abuse you have alleged in this case to any law enforcement agency, any child protective agency or any defendant, please state the employer of the person who made the report. PROVIDED ANSWER
INTERROGATORY NO. 166:
For each instance in which a report was made by any person concerning the sexual abuse you have alleged in this case to any law enforcement agency, any child protective agency or any defendant, please state the date of report made. PROVIDED ANSWER
INTERROGATORY NO. 167:
For each instance in which a report was made by any person concerning the sexual abuse you have alleged in this case to any law enforcement agency, any child protective agency or any defendant, please state the type of report made. PROVIDED ANSWER
INTERROGATORY NO. 168:
For each instance in which a report was made by any person concerning the sexual abuse you have alleged in this case to any law enforcement agency, any child protective agency or any defendant, please state the name of the person for whom the report was made. PROVIDED ANSWER
INTERROGATORY NO. 169:
For each instance in which a report was made by any person concerning the sexual abuse you have alleged in this case to any law enforcement agency, any child protective agency or any defendant, please state the address of the person for whom the report was made. PROVIDED ANSWER
INTERROGATORY NO. 170:
For each instance in which a report was made by any person concerning the sexual abuse you have alleged in this case to any law enforcement agency, any child protective agency or any defendant, please state the telephone number of the person for whom the report was made. PROVIDED ANSWER
INTERROGATORY NO. 171:
Do you or anyone acting on your behalf contend that any party to this case violated any statute, ordinance, or regulation and that the violation was a legal (proximate) cause of the sexual abuse you have alleged in this case? PROVIDED ANSWER
INTERROGATORY NO. 172:
If you or anyone acting on your behalf contend that any party to this case violated any statute, ordinance, or regulation and that the violation was a legal (proximate) cause of the sexual abuse you have alleged in this case, please identify the party or parties. PROVIDED ANSWER
INTERROGATORY NO. 173:
If you or anyone acting on your behalf contend that any party to this case violated any statute, ordinance, or regulation and that the violation was a legal (proximate) cause of the sexual abuse you have alleged in this case, please identify the statute, ordinance or regulation. PROVIDED ANSWER
INTERROGATORY NO. 174:
Was any person cited or charged with a violation of any statute, ordinance, or regulation as a result of the sexual abuse you have alleged in this case? COURT RULED NO RESPONSE NECESSARY
INTERROGATORY NO. 175:
If a person was cited or charged with a violation of any statute, ordinance, or regulation as a result of the sexual abuse you have alleged in this case, please state the name of the person. COURT RULED NO RESPONSE NECESSARY
INTERROGATORY NO. 176:
If a person was cited or charged with a violation of any statute, ordinance, or regulation as a result of the sexual abuse you have alleged in this case, please state the address of the person. COURT RULED NO RESPONSE NECESSARY
INTERROGATORY NO. 177:
If a person was cited or charged with a violation of any statute, ordinance, or regulation as a result of the sexual abuse you have alleged in this case, please state the telephone number of the person. COURT RULED NO RESPONSE NECESSARY
INTERROGATORY NO. 178:
If a person was cited or charged with a violation of any statute, ordinance, or regulation as a result of the sexual abuse you have alleged in this case, please state the statute, ordinance, or regulation allegedly violated. COURT RULED NO RESPONSE NECESSARY
INTERROGATORY NO. 179:
If a person was cited or charged with a violation of any statute, ordinance, or regulation as a result of the sexual abuse you have alleged in this case, please state what plea the person entered in response to the citation or charge. COURT RULED NO RESPONSE NECESSARY
INTERROGATORY NO. 180:
If a person was cited or charged with a violation of any statute, ordinance, or regulation as a result of the sexual abuse you have alleged in this case, please state the name of the court or administrative agency. COURT RULED NO RESPONSE NECESSARY
INTERROGATORY NO. 181:
If a person was cited or charged with a violation of any statute, ordinance, or regulation as a result of the sexual abuse you have alleged in this case, please state the address of the court or administrative agency. RESPONDED WITH OBJECTION ONLY
INTERROGATORY NO. 182:
If a person was cited or charged with a violation of any statute, ordinance, or regulation as a result of the sexual abuse you have alleged in this case, please state the names of the parties. RESPONDED WITH OBJECTION ONLY
INTERROGATORY NO. 183:
If a person was cited or charged with a violation of any statute, ordinance, or regulation as a result of the sexual abuse you have alleged in this case, please state the case number. RESPONDED WITH OBJECTION ONLY
INTERROGATORY NO. 184:
Identify all entities which have paid for medical and psychological expenses you have incurred as a result of the sexual abuse you have alleged in this case. PROVIDED ANSWER
INTERROGATORY NO. 185:
Of the medical and psychological expenses you have incurred as a result of the sexual abuse you have alleged in this case, state the amount that has been paid by you. PROVIDED ANSWER
INTERROGATORY NO. 186:
Of the medical and psychological expenses you have incurred as a result of the sexual abuse you have alleged in this case, state the amount that has been paid by any entities other than yourself. PROVIDED ANSWER
INTERROGATORY NO. 187:
For each personal injury or substantial physical, emotional, psychological or psychiatric trauma suffered at any time in your life, state the date of the trauma. PROVIDED ANSWER
INTERROGATORY NO. 188:
For each personal injury or substantial physical, emotional, psychological or psychiatric trauma suffered at any time in your life, state the location where the trauma occurred. PROVIDED ANSWER
INTERROGATORY NO. 189:
For each personal injury or substantial physical, emotional, psychological or psychiatric trauma suffered at any time in your life, state the nature of the trauma. PROVIDED ANSWER
INTERROGATORY NO. 190:
For each personal injury or substantial physical, emotional, psychological or psychiatric trauma suffered at any time in your life, state the name or whereabouts of any witnesses. PROVIDED ANSWER
INTERROGATORY NO. 191:
For each personal injury or substantial physical, emotional, psychological or psychiatric trauma suffered at any time in your life, state the present address or whereabouts of any witnesses. PROVIDED ANSWER
INTERROGATORY NO. 192:
For each personal injury or substantial physical, emotional, psychological or psychiatric trauma suffered at any time in your life, state the name of the HEALTH CARE PROVIDER(s) who examined and/or treated you for the trauma. PROVIDED ANSWER
INTERROGATORY NO. 193:
For each personal injury or substantial physical, emotional, psychological or psychiatric trauma suffered at any time in your life, state the address of the HEALTH CARE PROVIDER(s) who examined and/or treated you for the trauma. PROVIDED ANSWER
INTERROGATORY NO. 194:
If you contend that any defendant knew or had reason to know or was otherwise on notice that the ACCUSED PERSON(S) engaged in unlawful sexual conduct or was likely to engage in unlawful conduct prior to any of the act(s) of childhood sexual abuse that you allege in this case, for each defendant state all the facts that support this contention. PROVIDED ANSWER
INTERROGATORY NO. 195:
If you contend that any defendant knew or had reason to know or was otherwise on notice that the ACCUSED PERSON(S) engaged in unlawful sexual conduct or was likely to engage in unlawful conduct prior to any of the act(s) of childhood sexual abuse that you allege in this case, for each defendant state the dates when you contend that any defendant first obtained this information. PROVIDED ANSWER
INTERROGATORY NO. 196:
If you contend that any defendant knew or had reason to know or was otherwise on notice that the ACCUSED PERSON(S) engaged in unlawful sexual conduct or was likely to engage in unlawful conduct prior to any of the act(s) of childhood sexual abuse that you allege in this case, for each defendant identify all persons who have knowledge of facts PERTAINING TO this contention. PROVIDED ANSWER
INTERROGATORY NO. 197:
If you contend that any defendant knew or had reason to know or was otherwise on notice that the ACCUSED PERSON(S) engaged in unlawful sexual conduct or was likely to engage in unlawful conduct prior to any of the act(s) of childhood sexual abuse that you allege in this case, for each defendant identify all WRITINGS PERTAINING TO this contention. PROVIDED ANSWER
INTERROGATORY NO. 198:
If you contend that any defendant failed to take reasonable steps or to implement reasonable safeguards to avoid acts of unlawful sexual conduct by the ACCUSED PERSON(S) after any defendant knew or had reason to know or was otherwise on notice that the ACCUSED PERSON(S) engaged in unlawful sexual conduct or was likely to engage in unlawful conduct, for each defendant state all facts that support this contention. PROVIDED ANSWER
INTERROGATORY NO. 199:
If you contend that any defendant failed to take reasonable steps or to implement reasonable safeguards to avoid acts of unlawful sexual conduct by the ACCUSED PERSON(S) after any defendant knew or had reason to know or was otherwise on notice that the ACCUSED PERSON(S) engaged in unlawful sexual conduct or was likely to engage in unlawful conduct, for each defendant identify all persons who have knowledge of facts PERTAINING TO this contention. PROVIDED ANSWER
INTERROGATORY NO. 200:
If you contend that any defendant failed to take reasonable steps or to implement reasonable safeguards to avoid acts of unlawful sexual conduct by the ACCUSED PERSON(S) after any defendant knew or had reason to know or was otherwise on notice that the ACCUSED PERSON(S) engaged in unlawful sexual conduct or was likely to engage in unlawful conduct, for each defendant identify all WRITINGS that pertain to this contention. PROVIDED ANSWER
INTERROGATORY NO. 201:
If you contend that any defendant had actual knowledge, a specific warning, and/or knowledge of unambiguous conduct or other factors amounting to a specific warning that the ACCUSED PERSON(S) had engaged in unlawful sexual conduct or was likely to engage in unlawful conduct prior to any of the acts of childhood sexual abuse that you allege in this case, for each defendant state all facts that support this contention. PROVIDED ANSWER
INTERROGATORY NO. 202:
If you contend that any defendant had actual knowledge, a specific warning, and/or knowledge of unambiguous conduct or other factors amounting to a specific warning that the ACCUSED PERSON(S) had engaged in unlawful sexual conduct or was likely to engage in unlawful conduct prior to any of the acts of childhood sexual abuse that you allege in this case, for each defendant state the dates when you contend that any defendant first obtained this information. PROVIDED ANSWER
INTERROGATORY NO. 203:
If you contend that any defendant had actual knowledge, a specific warning, and/or knowledge of unambiguous conduct or other factors amounting to a specific warning that the ACCUSED PERSON(S) had engaged in unlawful sexual conduct or was likely to engage in unlawful conduct prior to any of the acts of childhood sexual abuse that you allege in this case, for each defendant identify all persons who have knowledge PERTAINING TO this contention. PROVIDED ANSWER
INTERROGATORY NO. 204:
If you contend that any defendant had actual knowledge, a specific warning, and/or knowledge of unambiguous conduct or other factors amounting to a specific warning that the ACCUSED PERSON(S) had engaged in unlawful sexual conduct or was likely to engage in unlawful conduct prior to any of the acts of childhood sexual abuse that you allege in this case, for each defendant identify all WRITINGS that pertain to this contention. PROVIDED ANSWER
INTERROGATORY NO. 205:
If you have ever filed or are a party to bankruptcy proceedings, please identify the court in which those proceedings were filed. PROVIDED ANSWER
INTERROGATORY NO. 206:
If you have ever filed or are a party to bankruptcy proceedings, please provide the docket or case number(s) assigned to those proceedings. PROVIDED ANSWER
INTERROGATORY NO. 207:
If you have ever filed or are a party to bankruptcy proceedings, please explain the status of the proceedings. PROVIDED ANSWER
INTERROGATORY NO. 208:
Please state your income for the past fifteen (15) years. PROVIDED ANSWER
INTERROGATORY NO. 209:
Please state with particularity the source of your income for the past fifteen (15) years. PROVIDED ANSWER
INTERROGATORY NO. 210:
Please state with particularity all injuries for which you seek recovery in this lawsuit. PROVIDED ANSWER
INTERROGATORY NO. 211:
Please identify all persons who have knowledge of the injuries for which you seek recovery in this lawsuit. PROVIDED ANSWER
INTERROGATORY NO. 212:
Identify by case name all proceedings in which you have given a statement under oath, including statements made in a declaration, affidavit, deposition or other testimony. PROVIDED ANSWER
INTERROGATORY NO. 213:
Identify by case or docket number all proceedings in which you have given a statement under oath, including statements made in a declaration, affidavit, deposition or other testimony. PROVIDED ANSWER
INTERROGATORY NO. 214:
Identify by court all proceedings in which you have given a statement under oath, including statements made in a declaration, affidavit, deposition or other testimony. PROVIDED ANSWER
NO. 215:
Identify by date all proceedings in which you have given a statement under oath, including statements made in a declaration, affidavit, deposition or other testimony. PROVIDED ANSWER

(The City of Angels is Everywhere)