Pleadings & Motions Writing Samples

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-1- COMPLAINT

JOHANN CHRISTINE ALCARAZ (Bar No. 1234567) SFSU LEGAL EXTENSION 835 Market St. San Francisco, California 94103 Telephone: 415 405 7700 Facsimile: 415 371 1012 Email: [email protected] Attorney for Rachel Smith

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF MARIN

Rachel Smith,

Plaintiff, v. Robert Jones, City of Mill Valley, and Does 1 through 10,

Defendants.

Case No. 1234567 Limited Civil Case COMPLAINT FOR DAMAGES

Plaintiff Rachel Smith (“Smith”) brings this claim against defendants Robert Jones

(“Jones”) and City of Mill Valley (“Mill Valley”), and allege as follows:

JURISDICTION

1. This court has jurisdiction under Article 6 of the California Constitution, which provides

for original and general jurisdiction for the superior courts.

VENUE

2. Venue is proper pursuant to CCP §394 and CCP §395 because Mill Valley is situated in

Marin County and the injury occurred in the same county.

PARTIES

3. Smith is, and at all time relevant herein was, a resident of the County of Marin,

California.

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-2- COMPLAINT

4. Jones is, and at all time relevant herein was, a resident of the County of Sonoma,

California.

5. Mill Valley is, and at all time relevant herein was, a public entity.

6. The true names and capacities of Does 1 through 10 herein are unknown to Smith at this

time, and Smith therefore sues such defendants by these fictitious names. At the time that the true

names and capacities of Does 1 through 10 are ascertained, Smith will amend this Complaint to

identify the true names.

STATEMENT OF FACTS COMMON TO ALL CAUSES OF ACTION

7. On August 25, 2015, at approximately 3:55 p.m., an officer was dispatched to a major

injury traffic collision that occurred at the intersection of Summit Ave. and Tamalpais Ave. Smith

was driving a Toyota Camry vehicle northbound on Summit Ave. turning left on Tamalpais Ave.

in Mill Valley, California. Jones was riding a bike southbound on Summit Ave. towards the same

intersection.

8. Smith stated that she observed Jones and a fellow biker approaching at high speed as she

made an early turn on Tamalpais Ave. As a result, she hit the brakes to stop in hopes that the

bikers could avoid her.

9. In a letter written by Smith a week after the incident (September 1), she mentions that

she tried to help Jones, but he said he was fine and the fault was not hers. Because he said he was

ok, she drove home.

10. Smith also states that she left for college shortly after the collision under the

impression that Jones was not injured. Upon discovering the contrary, she was overwhelmed with

guilt and emotional distress, and could no longer effectively focus on her schoolwork. She also

began to feel discomfort in her spine and neck which began affecting her part-time job of being a

restaurant server. After consultation at a clinic, the presiding chiropractor deemed the collision to

be the immediate source judging by the proximity of time.

11. Jones stated that he was riding at 15 to 20 miles per hour southbound on Summit Ave.

He admits that this was his first time riding the trail, and was on and off the brakes as he

approached Tamalpais Ave. He believes he was off the brakes when Smith’s vehicle came into

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-3- COMPLAINT

view, but acknowledges that his fingers were on the brake handles. So, approximately 30 to 60

feet before impact, he applied his brakes. Jones struck Smith’s vehicle behind the right wheel.

Before impact, he fell onto the ground, which caused him to summon aid at a nearby residence.

12. According to the Traffic Collision Report, Jones was taken by the paramedics to a

general hospital for the following injuries: broken left arm (compound), bruised left hip, and

abrasions.

13. The investigating officers of the incident reported that “it is unlikely that someone who

has never been on this road would take [the Tamalpais] corner at a speed any greater than 15 miles

per hour.”

FIRST CAUSE OF ACTION

(NEGLIGENCE)

14. Plaintiff Smith realleges paragraphs 1 through 13.

15. Prior to the collision, on Sunday, August 19, 2015, an article in Petaluma Weekly

illustrates a struggle between Jones and a NASCAR engine-shop employee, Larry Lackey. In the

article, Jones claims to have been sucker-punched by Lackey sustaining injuries of a broken left

arm and a black left eye.

16. Smith alleges Jones was negligent for failure to use reasonable care in determining his

riding speed in an area he admits to not have ridden before, while also naturally recuperating from

injuries sustained less than a week prior to the incident.

17. Jones told smith he was ok and the collision was not her fault; so, she left for college

under the impression that he was not injured. When she discovered that was not the case, she was

overcome with overwhelming guilt and emotional distress, which affected her ability to focus in

school.

18. Smith also began experiencing discomfort in her spine and neck shortly after leaving

for college. She visited a clinic and was told that her sudden stop in an effort to avoid the collision

may have misaligned her vertebra.

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-4- COMPLAINT

SECOND CAUSE OF ACTION

(DANGEROUS CONDITION OF PUBLIC PROPERTY)

19. Plaintiff Smith realleges paragraphs 1 through 18.

20. The Traffic Collision Report of the incident marks the “Roadway Conditions” as

having no controls present and noting hazardous material present. The Collision Narrative

explicates that “there are no traffic controls” and “there is no lane divider at the scene of the

collision or immediately adjacent to it.”

21. On or about September 19, 2015, roughly three weeks after the collision incident, a

written Claim for Damages setting forth the matters herein alleged was duly and regularly

presented to and filed on behalf of plaintiff Smith with defendant Mill Valley, in accordance with

the Tort Claims Acts (i.e., Government Code §945.4).

22. On or about November 7, 2015, Mill Valley mailed a letter rejecting these claims.

23. The complaint in this matter is timely filed within the time prescribed by law after

denial of said claim.

24. At all times herein mentioned, agents of defendant Mill Valley and Does 1 through 10,

inclusive, and each of them, knew that that roads of Summit Ave. and Tamalpais Ave. were

commonly used as public streets by vehicles and bikers.

25. The intersection presents a dangerous condition of public property in that it lacked the

aforementioned traffic controls and markings in addition to a 20% increase in downgrade going

southbound on Summit Ave—the same direction Jones was riding his bike. Additionally, the

Collision Narrative notes that the Tamalpais-Summit intersection “is at a curve so the sight line is

limited”.

26. Due to the limited sight distance of approximately 70 ft., Smith’s early left-turn did not

initially allow her to see Jones approaching. However, once she caught sight of him, she chose to

evade collision by stopping in hopes that Jones would avoid her. But, with his high riding speed in

conjunction with the decreasing downgrade and lack of traffic controls, Jones’ reaction time slot

was not conducive to a collision evasion, thus sustaining immediate injuries for him and delayed

injuries for Smith.

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-5- COMPLAINT

27. At all times herein mentioned, defendant Mill Valley and Does 1 through 10, inclusive,

knew or should have known about the current conditions of these roads and the respective

intersection.

REQUEST FOR RELIEF

28. WHEREFORE, Smith prays for judgment against the defendants, and each of them, as

hereinafter set forth:

1. For general damages in an amount to be proven at trial;

2. For special damages in an amount to be proven at trial;

3. For prejudgment interest as provided by law;

4. For costs of suit, expenses, and attorneys’ fees incurred herein;

5. For such other and further relief as the Court deems just and proper.

Dated: June 28, 2016 SFSU LEGAL EXTENSION By: JOHANN ALCARAZ

Attorney for Rachel Smith

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-1- ANSWER

JOHANN CHRISTINE ALCARAZ (Bar No. 1234567) SFSU LEGAL EXTENSION 835 Market St. San Francisco, California 94103 Telephone: 415 405 7700 Facsimile: 415 371 1012 Email: [email protected] Attorney for Respondent RACHEL SMITH


COUNTY OF MARIN

RACHEL SMITH (“Smith”, “Respondent”, or “Defendant”) answers the Complaint of

ROBERT JONES (“Jones”, “Petitioner”, or “Plaintiff”), and each and every allegation therein, as

follows:

1. Respondent lacks sufficient information or belief to admit or deny the allegations, and

on that basis denies each and every allegation of Paragraph 1 of the Complaint.

2. Respondent admits the allegations of Paragraph 2 of the Complaint.

3. Respondent admits the allegations of Paragraph 3 of the Complaint.

4. Respondent denies each and every allegation of Paragraphs 4, 5, and 6 of the Complaint.

FIRST AFFIRMATIVE DEFENSE

(Contributory Negligence)

Plaintiff was careless, negligent, or otherwise at fault with respect to the matters alleged in

the Complaint, and that such carelessness, negligence, and fault legally contributed to the

happening of the incident and to the loss and damage alleged and complained of, completely

ROBERT JONES, an individual,

Petitioners, v. RACHEL SMITH, an individual,

Respondent.

Case No. ANSWER

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-2- ANSWER

barring or proportionately reducing Plaintiffs’ right of recovery herein, if any such right is found

to exist.

SECOND AFFIRMATIVE DEFENSE

(Statute of Limitations)

The Complaint, and each alleged cause of action set forth therein, is barred by the

applicable statutes of limitations.

THIRD AFFIRMATIVE DEFENSE

(Failure to Mitigate)

Plaintiff failed to take such steps, or took such steps, such that Plaintiffs’ damages, if any

there were, were not mitigated or were increased as a result of Plaintiffs’ conduct, and by virtue of

this failure, Plaintiffs’ recovery must be barred or reduced by those damages that Plaintiffs have

failed to mitigate.

FOURTH AFFIRMATIVE DEFENSE

(Assumption of Risk)

Assuming, arguendo, that Plaintiffs suffered any damages as alleged in the Complaint,

which this answering Defendant denies, Plaintiffs voluntarily and with knowledge assumed any

and all risk for injuries, losses, and/or damages as alleged in the Complaint.

FIFTH AFFIRMATIVE DEFENSE

(Failure to Notify)

As to any damages alleged, which damages this answering Defendant denies, there was a

failure to give notice within a reasonable time after Plaintiffs knew of them, or reasonably should

have known of them, thus barring any recovery against this answering Defendant under Plaintiffs’

Complaint and each alleged cause of action therein.

PRAYER

WHEREFORE, Respondent hereby requests that:

1. Plaintiff takes nothing by reason of their Complaint;

2. Judgment be entered in favor of this answering Defendant;

3. This answering Defendant be awarded fees and costs of suit; and

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-3- ANSWER

4. Such other and further relief as the Court deems just and proper.

Dated: July 5, 2016 SFSU LEGAL EXTENSION By: JOHANN ALCARAZ


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-1- NOTICE OF MOTION AND MOTION TO CHANGE VENUE



COUNTY OF SAN FRANCISCO

Robert Jones,

Plaintiff, v. Rachel Smith, City of Mill Valley, and Does 1 through 10,

Defendants.

Case No. 7654321 NOTICE OF MOTION AND MOTION TO CHANGE VENUE Hearing Date: August 15, 2016 Time: 9:30 A.M. Dept: 302 Judge: Hon. Harold E. Kahn Reservation Number 13579-01 Action Filed: June 28, 2016

TO THE PLAINTIFF AND HIS ATTORNEY OF RECORD:

PLEASE TAKE NOTICE that on August 15, 2016 at 9:30 A.M., in Department 302 of the

above court, located at 400 McAllister Street, San Francisco, California, Defendant RACHEL

SMITH will move the Court for an order transferring venue to the Count of Marin pursuant to

Code of Civil Procedure section 394 subdivision (a), section 395 subdivision (a), section 396a

subdivision (b), and section 397 subdivisions (a) and (c). The motion will be made on the grounds

that San Francisco Superior Court is not the proper Court for the trial of this action, and Marin

County Superior Court is the proper Court.

This motion will be based on this notice and motion, the accompanying memorandum of

points and authorities, and the pleadings and papers on file in this action.

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-2- NOTICE OF MOTION AND MOTION TO CHANGE VENUE

WHEREFORE, Defendant RACHEL SMITH prays that the motion be granted, and she be

granted such other and further relief as the Court may deem proper.



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-1- Memo. of Points and Auth. in Supp. of Defendant’s Mot. to Change Venue (Case No. 7654321)



COUNTY OF SAN FRANCISCO

Robert Jones,


Defendants.

Case No. 7654321 MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO CHANGE VENUE Hearing Date: August 15, 2016 Time: 9:30 A.M. Dept: 302 Judge: Hon. Harold E. Kahn Reservation Number 13579-01 Action Filed: June 28, 2016

INTRODUCTION

In his Complaint, Plaintiff ROBERT JONES (“Jones”) requests relief for Negligence

specifically towards Defendant RACHEL SMITH (“Smith”). He further requests relief for

Dangerous Condition of Public Property specifically towards Defendant CITY OF MILL

VALLEY (“Mill Valley”). Plaintiff erroneously filed the Complaint in the city and county of San

Francisco. Venue of the aforementioned Cause of Actions is governed by Code of Civil Procedure

sections 394 and 395, respectively. As such, proper venue is in the County of Marin. Therefore,

Defendant makes this motion to change venue to the County of Marin, and requests that the Court

grant this motion and order the case transferred to the County of Marin.

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STATEMENT OF THE CASE

On August 25, 2015, an officer was dispatched to a major injury traffic collision that

occurred between JONES and SMITH at the intersection of Summit Ave. and Tamalpais Ave. in

Mill Valley, California.

MILL VALLEY is, and at all times relevant herein was, a public entity located in the

County of Marin. Code of Civil Procedure section 3941 states that an action against a city has a

proper venue in the county where that respective city is situated. (Code Civ. Proc., § 394, subd.

(a).)

SMITH is, and at all times relevant herein was, a resident of the County of Marin.

JONES is, and at all times relevant herein was, a resident of the County of Marin.

JONES alleges that SMITH’s negligence caused him personal injury. Section 395 provides

that the proper court for personal injury proceedings is either in the county where the defendants

reside or the county where the injury occurs. (§395, subd. (a).)

The complaint was filed in San Francisco. Defendant SMITH does not consent to this

venue. According to section 396a, if it appears from the complaint that the superior court is not

the proper court, and unless the defendant consents, then the court where the action is commenced

shall, on its own motion or on motion of the defendant, transfer said action to the proper court.

(§396a, subd. (b).)

Furthermore, section 397 delineates the cases in which venue may be changed such as

“when the court designated in the complaint is not the proper court” and “when the convenience of

witnesses and the ends of justice would be promoted by the change.” (§397, subds. (a), (c).)

ARGUMENT

CALIFORNIA CODE OF CIVIL PROCEDURE SECTIONS 394 AND 395 GOVERN PROPER VENUE FOR BOTH CAUSE OF ACTIONS IN THIS CASE.

1 All further statutory references are to the Code of Civil Procedure.

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Based on JONES’ purported cause of actions, Negligence and Dangerous Condition of

Public Property, and pursuant to sections 394 and 395, the proper venue resides in the county

where (1) the defendant SMITH resides, (2) the injury occurs, or (3) the public entity defendant

MILL VALLEY is situated. As such, the county of Marin satisfies all three possibilities thus being

the proper venue.

CONCLUSION

Venue was erroneously placed in the county of San Francisco. Venue is governed by

application of Code of Civil procedure sections 394 and 395, and the grounds to transfer venue is

substantiated by sections 396a and 397. For the foregoing reasons, defendant SMITH respectfully

requests that this Court grant her motion and transfer this matter to Marin County Superior Court.



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-1- Plaintiff’s Notice of Motion & Motion to Compel (Case No. 7654321)

JOHANN CHRISTINE ALCARAZ (Bar No. 1234567) SFSU LEGAL EXTENSION 835 Market St. San Francisco, California 94103 Telephone: 415 405 7700 Facsimile: 415 371 1012 Email: [email protected] Attorney for Robert Jones


COUNTY OF MARIN

Robert Jones,


Defendants.

DISCOVERY MOTION Case No. 7654321 ROBERT JONES’ NOTICE OF MOTION AND MOTION TO COMPEL RESPONSES TO SPECIAL INTERROGATORIES, SET ONE Hearing Date: September 7, 2016 Time: 1:30 P.M. Dept: B Judge: Hon. Roy O. Chernus Trial Date: TBD Action Filed: March 28, 2016

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-2- Plaintiff’s Notice of Motion & Motion to Compel (Case No. 7654321)

TO DEFENDANT RACHEL SMITH AND HER ATTORNEY OF RECORD:

PLEASE TAKE NOTICE that on September 7, 2016 at 1:30 P.M., in Department B of the

above court, located at 3501 Civic Center Drive, San Rafael, California, plaintiff ROBERT

JONES will move the Court for an order compelling defendant RACHEL SMITH to provide

responses to plaintiff’s SPECIAL INTERROGATORIES, SET ONE pursuant to Code of Civil

Procedure section 2030.290 subdivision (b). This motion is made on the grounds that defendant

failed to serve a timely response within thirty (30) days in accordance with Code of Civil

Procedure section 2030.260.

This motion will be based upon this Notice and Motion, the accompanying Memorandum

of Points and Authorities in Support of Motion, Declaration of Attorney Johann Christine Alcaraz,

and the pleadings and papers on file in this action.

WHEREFORE, plaintiff ROBERT JONES prays that the motion be granted, and he be

granted such other and further relief as the Court may deem proper.

Dated: August 1, 2016 SFSU LEGAL EXTENSION By: JOHANN CHRISTINE ALCARAZ

Attorney for Robert Jones

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-1- Memo. of Points and Auth. in Supp. of Plaintiff’s Mot. to Compel (Case No. 7654321)



COUNTY OF MARIN

Robert Jones,


Defendants.

DISCOVERY MOTION Case No. 7654321 MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF PLAINTIFF'S MOTION TO COMPEL RESPONSES TO SPECIAL INTERROGATORIES, SET ONE Hearing Date: September 7, 2016 Time: 1:30 P.M. Dept: B Judge: Hon. Roy O. Chernus Trial Date: TBD Action Filed: March 28, 2016

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INTRODUCTION

With this Motion, plaintiff ROBERT JONES (“JONES”) seeks an order against defendant

RACHEL SMITH (“SMITH”) compelling responses to SPECIAL INTERROGATORIES, SET

ONE served on June 30, 2016. To date, no response of any kind has been served to the plaintiff or

his attorney of record. As there is no legal or factual basis for defendant to refuse to provide any

substantive response whatsoever, JONES respectfully asks this Court to order defendant SMITH

to provide responses to JONES’ first set of interrogatories consistent with the requirements of

Code of Civil procedure section 2030.290 subdivision (b).

FACTUAL BACKGROUND1

On August 25, 2015, an officer was dispatched to a traffic collision that occurred between

JONES and SMITH at the intersection of Summit Ave. and Tamalpais Ave. in Mill Valley,

California. As a result of the collision, JONES suffered major injuries.

A. Plaintiff Initiates Action and Propounds Discovery

JONES filed the complaint on March 28, 2016 with claims of Negligence and Dangerous

Condition of Public Property against SMITH and CITY OF MILL VALLEY, respectively. On

June 20, 2016, plaintiff propounded written discovery requests, including SPECIAL

INTERROGATORIES, SET ONE and served to defendant SMITH’s attorney of record by

overnight mail. (Alcaraz Decl., ¶3, Exh. A.) There was no agreement set forth regarding any

extension of time for plaintiff to respond. (Id. at ¶3)

B. Meet and Confer Attempts Fail to Produce Responses

On July 15, 2016, twenty-five (25) days after serving the written discovery requests,

defendant’s attorney checked in to touch base with plaintiff’s counsel via email to no avail.

(Alcaraz Decl., ¶4, Exh. B.) In an effort to comply with Code of Civil procedure section 2016.040

and Marin County Rule, Civil 1.13 subdivision (A), plaintiff and his counsel initiated a meet and

confer dialogue with defendant by letter on July 20, 2016—thirty days after the interrogatories

were served (the deadline to receive defendant’s responses). The letter indicated that if no 1 Unless otherwise indicated, all of the facts contained herein are supported by the accompanying Declaration of Johann Christine Alcaraz (“Alcaraz Decl.”).

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response is received by noon the next week (Wednesday, July 27), plaintiff would proceed with

filing a motion to compel (Id. at ¶5, Exh. C.) A week passed with no reply from the defendant or

her counsel. (Id. at ¶6.)

On July 27, 2016, with the deadline for filing a motion to compel pressing, plaintiff sent

defendant’s counsel a letter via email attachment to discuss available hearing dates for the Motion.

(Alcaraz Decl., ¶6, Exh. D.) Defendant’s counsel replied the next morning explaining that they

just returned from vacation and agreed to September 7, 2016 as the hearing date. No other

information was provided as to the defendant’s lack of response. (Ibid.)

ARGUMENT

CALIFORNIA CODE OF CIVIL PROCEDURE SECTION 2030.290 GOVERN PROPER PROTOCOL IN THE EVENT OF OPPOSING COUNSEL FAILING TO SERVE A

TIMELY RESPONSE

The situation is clear and simple: defendant SMITH and her counsel have failed to respond

to SPECIAL INTERROGATORIES, SET ONE propounded by plaintiff JONES on June 20, 2016.

Plaintiff and his counsel have attempted to show a reasonable and good faith attempt at an

informal resolution of the issue to no avail, and thus have initiated this Motion pursuant to Code of

Civil Procedure 2030.290 subdivision (b), which states: “The party propounding the

interrogatories may move for an order compelling response to the interrogatories” given that the

party to whom interrogatories are directed fails to serve a timely response. (Code Civ. Proc.,

§2030.290, subd. (b).)

CONCLUSION

For the foregoing reasons, JONES respectfully requests that this Court grant this Motion to

Compel and order defendant SMITH to provide a response to SPECIAL INTERROGATORIES,

SET ONE.

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Dated: August 1, 2016 SFSU LEGAL EXTENSION By: JOHANN CHRISTINE ALCARAZ

Attorney for ROBERT JONES

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-1- Declaration of Johann Christine Alcaraz in Support of Motion to Compel (Case No. 7654321)



COUNTY OF MARIN

Robert Jones,


Defendants.

DISCOVERY MOTION Case No. 7654321 DECLARATION OF ATTORNEY JOHANN CHRISTINE ALCARAZ IN SUPPORT OF ROBERT JONES’ MOTION TO COMPEL RESPONSES TO SPECIAL INTERROGATORIES, SET ONE Hearing Date: September 7, 2016 Time: 1:30 P.M. Dept: B Judge: Hon. Roy O. Chernus Trial Date: TBD Action Filed: March 28, 2016

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I, JOHANN CHRISTINE ALCARAZ, declare as follows:

1. I am an attorney at law duly licensed to practice before all courts in the State of

California. I am an attorney at the SFSU Legal Extension and counsel of record for plaintiff

ROBERT JONES in this matter. I have personal knowledge of the facts stated below, and if called

upon as a witness, I could and would testify competently thereto. I submit this declaration in

support of the plaintiff’s Motion to Compel Responses to SPECIAL INTERROGATORIES, SET

ONE.

2. This matter involves a Negligence action specifically towards defendant RACHEL

SMITH relating to a traffic collision incident at the intersection of Summit Ave. and Tamalpais

Ave. in Mill Valley, California that occurred on August 25, 2015.

3. On June 20, 2016, I served ROBERT JONES’ SPECIAL INTERROGATORIES

TO RACHEL SMITH, SET ONE on defendant’s counsel by overnight mail. Attached hereto as

Exhibit A is a true and correct copy of JONES’ Interrogatories. There was no correspondence

relating to an extension of time for serving a response.

4. On July 15, 2016, since a lack of correspondence ensued and the response deadline

was nearing (five (5) days away), I emailed opposing counsel just to touch base and check in on

the status of their responses. Attached hereto as Exhibit B is a true and correct copy of my July 15,

2016 email. I did not receive a reply.

5. On July 20, 2016, I sent a letter to defendant’s counsel to meet and confer

regarding defendant’s response to SPECIAL INTERROGATORIES, SET ONE. In my letter, I

asked counsel to contact me by the following Wednesday, July 27, 2016, to let me know whether

defendant will be providing a response of any kind or if an extension will be needed. I also

advised that if I did not receive a response by July 27, I would proceed with filing a motion to

compel. Attached hereto as Exhibit C is a true and correct copy of my July 20, 2016 letter.

6. I did not receive a response by July 27, 2016. Given the approaching deadline to

file a motion to compel, I emailed defendant’s counsel a letter that day (Wednesday, July 27,

2016) notifying them of the initiation of the motion to compel. I also advised plaintiff concerning

available court dates for hearing Jones’ Motion. Defendant’s counsel finally replied the morning

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after (July 28, 2016) explaining that they had just returned from vacation and that defendant

agreed to September 7, 2016 as the hearing date for Jones’ Motion. Attached hereto as Exhibit D

is a true and correct copy of the email thread (and attached letter) between myself and defendant’s

counsel.

I declare under penalty of perjury under the laws of the State of California that the

foregoing is true and correct.

Executed this 2nd day of August 2016, at San Francisco, California.

SFSU LEGAL EXTENSION By: JOHANN CHRISTINE ALCARAZ

Attorney for ROBERT JONES

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-1- Plaintiff Robert Jones’ Special Interrogatories – SET ONE (Case No. 7654321)



COUNTY OF MARIN

Robert Jones,


Defendants.

Case No. 7654321 ROBERT JONES’ SPECIAL INTERROGATORIES TO RACHEL SMITH, SET ONE Trial Date: TBD Action Filed: March 28, 2016

PROPOUNDING PARTY: Plaintiff Robert Jones

RESPONDING PARTY: Defendant Rachel Smith

SET NO.: ONE (1)

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-2- Plaintiff Robert Jones’ Special Interrogatories – SET ONE (Case No. 7654321)

Pursuant to Code of Civil Procedure section 2030.010 et seq., plaintiff ROBERT JONES

(“Jones”) hereby requests that defendant RACHEL SMITH (“Smith”) respond fully, in writing,

and under oath to the following Special Interrogatories within thirty (30) days after service.

SPECIAL INTERROGATORIES

SPECIAL INTERROGATORY NO. 1:

IDENTIFY the name and quantity of each type of drug or medication taken or used by

YOU during the last six (6) months, specifying the frequency and purpose of use.

SPECIAL INTERROGATORY NO. 2:

IDENTIFY the approximate/average frequency in which YOU personally drive through or

drive past the intersection of Summit Avenue and Tamalpais Avenue located in Mill Valley,

California in any given month within the past year.

Dated: June 20, 2016 SFSU LEGAL EXTENSION By: JOHANN CHRISTINE ALCARAZ

Attorney for Robert Jones

Pleadings & Motions Writing Samples

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