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James Alan Bush (DWF967-08086698) 885 North San Pedro Avenue San Jose, California 95110 Plaintiff in pro per

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

James Alan Bush, Plaintiff, v. Officer Miguel Flores (#3881), Defendant.

Case No. 09-cv-01024 (PR) RS PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT CAZMO J. LUKRICH, M.D. [Fed. R. Civ. P., Rule 33] Judge Richard Seeborg

COMES NOW, James Alan Bush, the plaintiff in the above-captioned matter, and submits the following interrogatories to Cazmo J. Lukrich, M.D., to be answered under oath, pursuant to Rule 33 of the Federal Rules of Civil Procedure, which pertain to the injuries sustained by the plaintiff during the course of his arrest, which occurred on or around December 12th, 2008: I. INSTRUCTIONS A. In answering these interrogatories, please include all relevant documents that support your answers. B. Please file your answers with the Clerk of the United States PAGE 1 OF 4 09-cv-01024 (PR) RS

INTERROGATORIES

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District Court, located at 280 South First Street, Room 2112, in San Jose, within 30 days from the date these interrogatories were submitted. II. DEFINITIONS A. B. PLAINTIFF means the named PLAINTIFF in this case. DEFENDANT means the named DEFENDANT in this case, who is also the officer who effected the arrest of the PLAINTIFF that is the subject of these interrogatories. DOCUMENT means a writing, and includes the original or a copy of handwriting, typewriting, printing (including computer printouts), photostating, photographing; every other means of recording upon any tangible thing; and every form of written communication or representation, including letter, words, pictures, sounds, symbols, or combination of these. INJURY refers to any physical illness, disability, or other kind of ailment, PLAINTIFF claims to have suffered by the use of force applied by DEFENDANT during the course of the arrest of PLAINTIFF. PERSON means any natural PERSONS, including jail officials, employees, supervisors, agents, and representatives. IDENTIFY A PERSON means to state his or her full name; business affiliation; business telephone number; business address; title and professional designation (e.g., M.D.), if known. MEDICAL CARE includes any aid, treatment, comfort, diagnosis, prognosis, or examination by any MEDICAL CARE PROVIDER or other PERSON for any INJURY. MEDICAL CARE PROVIDER includes all PERSONS who provided any type of MEDICAL CARE on a professional basis, such as physicians, INTERROGATORIES PAGE 2 OF 4 09-cv-01024 (PR) RS

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surgeons, nurses, nurses’ aides, technicians, paramedics, and other medical specialists. III. INTERROGATORIES 1. Please describe the nature and extent of PLAINTIFF’S INJURIES to his rib, which you indicated previously to PLAINTIFF was fractured and shattered. Do you contend that the INJURIES to PLAINTIFF’S rib occurred as a result of the use of force applied by the DEFENDANT during the course of PLAINTIFF’S arrest? If your answer to Interrogatory #2 is yes, please describe the type of force likely to have been applied by DEFENDANT, which you identified as the cause of PLAINTIFF’S INJURIES, was excessive and/ or atypical among other persons to which similar force has been applied. Please describe the nature and extent of PLAINTIFF’S INJURIES to his shoulder, which you indicated previously to PLAINTIFF was damaged. Do you contend that the INJURIES to PLAINTIFF’S shoulder occurred as a result of the use of force applied by the DEFENDANT during the course of PLAINTIFF’S arrest? If your answer to Interrogatory #6 is yes, please describe the type of force likely to have been applied by DEFENDANT that would have resulted in the INJURIES you described in Interrogatory #5. If your answer to Interrogatory #6 is yes, please indicate whether you believe that force applied by DEFENDANT, which you identified as the cause of PLAINTIFF’S INJURIES, was excessive and/or atypical among other persons to which similar force has been applied. INTERROGATORIES PAGE 3 OF 4 09-cv-01024 (PR) RS

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8.

IDENTIFY ALL PERSONS and MEDICAL CARE PROVIDERS, including yourself, who provided MEDICAL CARE for PLAINTIFF’S INJURIES at any time during the period from December 12th, 2008, to present.

9.

For each PERSON or MEDICAL CARE PROVIDER listed in Interrogatory #9, state his or her job title, duties, and responsibilities (where applicable).

10. For each PERSON or MEDICAL CARE PROVIDER listed in Interrogatory #9, describe the training and experience each had in order to perform the duties of the position (where applicable). Submitted this 20th day of September, 2009.

James Alan Bush Plaintiff in pro per

INTERROGATORIES

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09-cv-01024 (PR) RS

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