Model Interrogatories

Description

Your First Draft Will Read Like a Polished Final Copy!

Model Interrogatories gives you over 4,500 practice-tested models that have been used and revised several times and can be easily adapted to suit your needs.  Efficiently tailor your discovery in a wide variety of cases. Quickly customize interrogatories for:

• Vehicular negligence
• Sexual harassment
• Insurance bad faith
• Premises liability
• Product liability
• Legal malpractice
• Wrongful termination
• Age discrimination
• Wrongful death and survival actions
• Medical malpractice
• Governmental tort liability
• Liability insurance: agent and broker liability
• Malicious prosecution
• Workplace violence
• Fraud and deceit
• Elder abuse
• ADA claims
• Interference with business relations
• And more!

Coverage in key practice areas helps you construct precise, winning questions for plaintiffs or defendants. Narrow extensive discovery and prevail. You will get more complete answers with the direct phrasing of the questions, which will reduce the number of objections and non-responsive answers. The extensive checklists will bring to mind fertile topics for exploration and highlight the best areas of inquiry.

Seven reasons to try:

1. Saves time. Customizing pre-drafted questions can save you hours.
2. Covers over 25 different types of cases. These interrogatories tackle the tough legal issues that arise in a variety of cases, from auto negligence to insurance bad faith to premises liability.
3. Better answers. Each stand-alone interrogatory is direct, clear and goes straight to the heart of the information critical to your case. You’ll elicit more complete answers, avoid objections, and reduce the number of non-responsive answers.
4. More efficient discovery. You’ll acquire more information with less effort and expense by using these interrogatories to guide your format and substantive coverage.
5. Free access to digital forms via an emailed zip file including every interrogatory printed in the book. Speed production by inserting selected questions directly into your discovery.
6. Better utilize your staff. The book is so easy to use, your staff can prepare comprehensive discovery with relatively minor supervision.
7. Improve your standard interrogatories. Use Kevin Culhane’s clearly phrased questions and definitions to supplement interrogatory sets you use repeatedly.

REVISION 16 HIGHLIGHTS

This new Edition of Model Interrogatories adds a new chapter:

New Chapter 34 Dental Malpractice

Elements of Plaintiff’s Cause of Action
Information Regarding the Parties
Defendant’s Relationship to Plaintiff
Alleged Errors and Omissions
Causation
Defenses in Dental Malpractice Cases
Damages in Dental Malpractice Cases
Plaintiff’s Alleged Failure to Mitigate Damages
Investigatory Interrogatories
Due Diligence in Preparation of Response
Deposition Checklists

With this new update, Judge Kevin Culhane’s Model Interrogatories will continue to help you draft better interrogatories in novel fact patterns.

ABBREVIATED TABLE OF CONTENTS

CHAPTER 1 PRACTICE TIPS AND PRELIMINARY CONSIDERATIONS
CHAPTER 2 GENERAL INTERROGATORIES – BACKGROUND AND INVESTIGATION
CHAPTER 3 GENERAL INTERROGATORIES – DAMAGES, DEFENSES AND DENIALS
CHAPTER 4 VEHICULAR NEGLIGENCE
CHAPTER 5 PREMISES LIABILITY
CHAPTER 6 PRODUCT LIABILITY
CHAPTER 7 INSURANCE BAD FAITH
CHAPTER 8 LEGAL MALPRACTICE
CHAPTER 9 MALICIOUS PROSECUTION
CHAPTER 10 WRONGFUL DEATH AND SURVIVAL ACTIONS
CHAPTER 11 MEDICAL MALPRACTICE
CHAPTER 12 GOVERNMENTAL TORT LIABILITY
CHAPTER 13 WRONGFUL TERMINATION OF EMPLOYMENT
CHAPTER 14 CLAIMS UNDER THE AMERICANS WITH DISABILITIES ACT
CHAPTER 15 SEXUAL HARASSMENT
CHAPTER 16 AGE DISCRIMINATION
CHAPTER 17 WORKPLACE VIOLENCE
CHAPTER 18 FRAUD AND DECEIT
CHAPTER 19 OTHER INSURANCE CLAIMS
CHAPTER 20 ELDER ABUSE
CHAPTER 21 INTERFERENCE WITH BUSINESS RELATIONS
CHAPTER 22 LIABILITY INSURANCE: AGENT AND BROKER LIABILITY
CHAPTER 23 PRACTICE AND DISCOVERY UNDER THE ANTI-SLAPP STATUTES
CHAPTER 24 DEFAMATION
CHAPTER 25 INVASION OF PRIVACY
CHAPTER 26 BREACH OF CONTRACT
CHAPTER 27 CLAIMS UNDER THE UNIFORM FRAUDULENT TRANSFER ACT
CHAPTER 28 INTENTIONAL TORTS
CHAPTER 29 CLAIMS UNDER 42 U.S.C. SECTION 1983
CHAPTER 30 QUASI-CONTRACTS
CHAPTER 31 COMMON COUNTS
CHAPTER 32 DOMESTIC VIOLENCE
CHAPTER 33 GENDER-RELATED VIOLENCE
CHAPTER 34 DENTAL MALPRACTICE
INDEX

ABOUT THE AUTHOR

Hon. Kevin R. Culhane is a judge of the Sacramento Superior Court, where he has conducted law and motion, family law, and general trial assignments. Before assuming the bench, Judge Culhane was a partner at the Sacramento law firm of Hansen, Boyd, Culhane & Watson from 1977 to 2002, and Hansen, Culhane, Kohls, Jones & Sommer from 2002 to 2008. His practice consisted primarily of professional liability and appellate law. As a practitioner, Judge Culhane held an A-V rating from Martindale-Hubbell Law Directory.

He has been a visiting professor of Evidence and Torts at McGeorge School of Law in Sacramento, and is currently completing his 32nd year as an adjunct professor teaching Insurance Law, Professional Responsibility and Advanced Torts. He has been a faculty member at Hastings Center for Trial and Appellate Advocacy in San Francisco, and frequently lectured on discovery and trial matters for California’s Continuing Education of the Bar. He has an LLM from Stanford and his JD from McGeorge.

This full-time practice/part-time teaching combination helped Judge Culhane write a book useful to experienced practitioners and understandable to novices.

Judge Culhane was also a member of the California State Bar Board of Governors, and was active in his County Bar Association. As a practitioner, Judge Culhane was instrumental in establishing the California State Bar’s Professional Liability Insurance Program and served as the Chair of the Board of Governors Committee on Attorney Discipline. Before assuming the bench, he served a one-year term as Vice-President of the State Bar of California, and was appointed to two successive terms as a member of the Judicial Council of California.

Noteworthy cases of his include Benford v. Kawasaki (defective motorcycle sidestand, $825,000 plaintiff’s verdict); North Dakota v. Neville (U.S. Supreme Court appearance as amicus in DUI refusal); Potter v. Westfield (injury settlement exceeding $7 million); and 136 Families v. Coordinated Financial Planning (assets exceeding $1 million recovered from defendant). Reported appellate cases include Adams v. Paul (1995) 11 Cal.4th 583; Chirmside v. P.E.R.S. (1983) 143 Cal. App. 3d 205; Miofsky v. Schweiker (1983) 709 F.2d 1517; Municipal Court v. Superior Court (1992) 9 Cal. App. 4th 1867; Olney v. Sacramento Co. Bar Ass’n. (1989) 22 Cal. App. 3d 807 and CTLA v. Superior Court (1986) 187 Cal. App. 3d 575.