SPECIAL INTERROGATORIES Special Interrogatory #1 ======================== Primary care physician since Aug 2010: Peter Bullock 143 Birch St Redwood City, CA 650-366-1141 Before August 2010: David Resnick-Sannes 5403 Scotts Valley Drive #A Scotts Valley, CA 95066 831-438-5222 Special Interrogatory #2 ======================== PRIOR to the subject incident: In 2003-2004 I had two inguinal hernia surgeries at: Dominican Hospital 1555 Soquel Dr Santa Cruz, CA 95065 (831) 462-7700 Other than this nothing in particular comes to mind. The physicians above will have records that may reveal other things. AFTER the subject incident I have been treated at these places: Sequoia Hospital Emergency Room 170 Alameda de las Pulgas Redwood City, CA 94062 Peter Bullock, MD 143 Birch St Redwood City, CA Valley Radiology Medical Associates 801 Brewster Ave Suite 100 Redwood City, CA 94063 Evergreen Physical Therapy 155 Birch St Redwood City, CA 94062 Yfinite Wellness (acupunture) 10 El Camino Real, Suite 202 San Carlos, CA 94070 Special Interrogatory #3 ======================== David Steenson 650 Green Street San Francisco, CA 94133 650-207-3430 Special Interrogatory #4 ======================== No Special Interrogatory #5 ======================== Not applicable Special Interrogatory #6 ======================== No Special Interrogatory #7 ======================== At the time of the subject incident it was: Anthem Blue Cross Subscriber's Name: Jon G Bjornstad Id #: 276A62381 Group #: 06Z400 Group Name: SMALL GROUP PPO Currently, it is: Aetna Name: Jon G. Bjornstad ID: W2093 73411 Health Plan (80840) 9140860054 GRP: 805470-010-00700 Special Interrogatory #8 ======================== Matthew - you have the totals at the time of the submission of the complaint. Since then I have paid: $74.25 in 4 copays at the physical therapy office 3 $25 copays at Dr Bullock's office $25 for a toridol injection by Dr Bullock $70 for an X-Ray + an X-Ray related charge of $10.51 $270 for 4 acupunture appointments The insurance has likely paid more. Special Interrogatory #9 and #10 ================================ Yes, the insurance company and I have paid for the medical specials. Matthew - you have the EOBs you submitted. Special Interrogatry #11 ======================== There is no outstanding debt for the medical specials. DEMAND FOR INSPECTION AND PRODUCTION OF DOCUMENTS SET NO. 1 1 - all bills, reports, documents relating to examination, diagnosis, hospitalization .... relating to the accident Full authoritative documentation can be obtained from the facilities listed above. 2 - The police report is available - flawed though it is. 3 - I DO still have the damaged crankset from the accident. It shows that there was a collision of some force that bent the metal. It shows that the driver could NOT have JUST started from a full stop. 4 - I have the digital pictures I took of the scene of the accident and the path leading up to the scene. Shall I print them out? 5 - I have no images of my injured body. If I had taken an image it would have only showed extensive black-and-blue marks on my right buttock. The severe contusions to my hip, buttock and lower back didn't have much to show externally. 6 - Bicycle repairs: Parts New Crankset - 45.99 Bottom Bracket - 19.99 Pedals - 29.99 Labor Install crank - 30.00 Replace Bottom Bracket - 20.00 Sub Total - 145.97 4% tax - 5.83 Total - $151.80 7 - Vehicle loss of use claim? None 8 - Loss of earnings? None 9 - Any and all statements from the Demanding party? What does this mean? 10 - ... compliance with California Financial Responsiblity laws ... What does this mean? FORM INTERROGATORIES 1.1 Matthew Haberkorn ... 2.1a Jon Gregor Bjornstad 2.1b no other alias 2.1c not applicable 2.2 October 20, 1949 Grand Forks, North Dakota, USA 2.3a California 2.3b N7871556 Class C 2.3c 10/02/2010 2.3d Corrective Lens 2.4 Not applicable 2.5a 728 Hopkins Avenue, Redwood City, CA 94063 2.5b 514 Button Street, Santa Cruz, CA 95060 2.5c 2/2011 to present - Hopkins 8/2010 to 2/2011 - in transition - various rooms and motels 1/2009 to 8/2010 - Button 2.6a LiveOps, 555 Twin Dolphin Dr Suite 400, Redwood City, CA 94065 2.6b nature of work - software engineering 9/2013 to present LiveOps, 555 Twin Dolphin Dr Suite 400, Redwood City, CA 94065 12/2012 to 5/2013 SocialText, 558 Waverly St, Palo Alto, CA 94301 8/2010 to 10/2012 Vindicia, 303 Twin Dolphin Dr Suite 200, Redwood City, CA 94065 1/2009 to present Mount Madonna Center, 445 Summit Rd, Watsonville, CA 95076 2.7a-d Wilcox High School, Santa Clara, CA 95051 - high school diploma 9/1963 to 6/1967 UC at Santa Cruz, Santa Cruz, CA 95060 - BA in Mathematics 9/1967 to 6/1971 U of Maryland - MA in Mathematics 9/1971 to 6/1974 UC at Santa Cruz, Santa Cruz, CA 95060 - BA in Biology 9/1981 to 6/1984 2.8 No 2.9 Yes 2.10 Yes 2.11 No 2.12 No 2.13 No 4.1 No 4.2a Medical 4.2b Anthem Blue Cross Life and Health Insurance Company P.O. Box 60007 Los Angeles, CA 90060-0007 4.2c Jon G Bjornstad 728 Hopkins Avenue, Redwood City, CA 94063 415-246-6499 4.2d Id #: 276A62381 Group #: 06Z400 Group Name: SMALL GROUP PPO 4.2e Limits of coverage - I do not know - Contact the insurance company. 4.2f No 4.2g Custodian? I was insured through my employer - a contract house that had a 6 month contract with the company LiveOps. That employer was: The Armada Group 325 Soquel Ave, Santa Cruz, CA 95062 800-408-2120 6.1 Yes 6.2 Severe contusions to the right hip, buttock and lower back. 6.3 There is still some lingering tendonitis in the upper right gluteus maximus. It is worse in the morning. It is not truly handicapping but it is, at times, an annoying ache. This specific area is one that was injured in a bicycle accident in 1975 - slipping on a patch of ice while turning. I thought the injury from the accident on 11/21/2013 was healed by the end of the year but the tendonitis resurfaced at the end of February 2014. There was no further trauma just normal usage. Subsequent treatment by physical therapy, cortisone shot, and acupuncture have had limited effect. Today (6/21/2014) it does seem to finally be getting better after a series of consecutive icings and rest. It may be the case that the bicycle accident on 11/21/2014 weakened that area and made healing more difficult. This cannot, of course, be proved. 6.4 This question was answered in the special interrogatories, yes? 6.5 Advil Sequoia hospital emergency physician 11/21/2013 as needed for 4 weeks Cost? Naproxen Peter Bullock 3/1/2014 as needed for 6 weeks 10$? Toridol shot Peter Bullock 3/10/2014? one time $25 Cortisone shot Peter Bullock 4/1/2014? one time cost? 6.6 See special interrogatories 6.7 No 7.1 See the above list of bicycle repairs 7.2 7.3 8.1 No 9.1 No 9.2 Not applicable 10.1 As stated above in 6.3 there was a bicycle accident in 1975 that injured the same area of the right hip. The injury caused some tendonitis in the gluteus maximus or the sacro-iliitis joint that did heal at the time. I have been essentially asymptomatic for nearly 40 years since. This area seems to be my 'achilles heel'. 10.2 No 10.3 Not really. The injury on 11/21/2013 had apparently not completely healed. Matthew - please reword the answers to 10.1 and 10.3 as appropriate so as to not give the other side any opportunity to poke at me and claim they don't owe us any compensation. 11.1 No 11.2 No 12.1 See police report. 12.2 I spoke with the driver briefly after the accident. Details of that conversation are in my blog. I spoke briefly to David Steenson, the witness, on two occasions. One time after reading the police report to see if he agreed with the statement the policeman wrote. Another time on 6/16/2014 to inform him briefly of the lawsuit and that he may be deposed. Matthew - please reword the above. 12.3 No 12.4 I do have photographs of the scene of the accident that I took a few days after the incident. They are in my blog. I can provide high resolution versions of any that you wish. 12.5 See police report. 12.6 See police report. 12.7 I have visited the scene several times in the last few months. 13.1 No 13.2 Not applicable. 14.1 See police report. I WAS riding on the sidewalk prior to entering the crosswalk. This was noted in the report as a violation of a Redwood City ordinance. In my view this was not a cause of the accident - in part because the accident happened in the crosswalk not on the sidewalk. The witness (David Steenson) and I contend that the driver did not stop at the stop sign. This WAS the cause of the accident. I saw him approaching and slowing and I (unfortunately) assumed he would stop. 14.2 No 20.1 See police report. 20.2 See police report. 20.3 I began at my work place - 555 Twin Dolphin Drive, Suite 400, Redwood City. My destination was home - 728 Hopkins Avenue, Redwood City. 20.4 I exited the building at 555 Twin Dolphin Drive by the rear door and began riding my bike on the paths through the corporate parklike setting. I entered the birch-lined pathway leading from the EA headquarters to the place where it meets Redwood Shores Parkway. I have pictures of this location. There is short stretch of sidewalk and then a crosswalk. This is where the accident happened. I made no stops from the time I left work up until when the accident happened. 20.5 I was riding on the EA pathway to the sidewalk into the crosswalk. I was traveling west. The driver was exiting the parking lot at 201 Redwood Shores Parkway. He was traveling south. He approached the stop sign and crosswalk. 20.6 There was a stop sign before the crosswalk. I have pictures. The signage (saying "STOP") on the road itself was faded out. The stop sign itself was smaller than is standard. 20.7 No. 20.8 I approached the crosswalk at a speed of approximately 7 mph or less. I do remember that number on the speedometer on the bike. I saw a car approaching. It was slowing for the stop sign. I (unfortunately) assumed it would stop so I proceeded into the crosswalk. The car did not stop and hit me. The collision occurred within the crosswalk. I do not know how fast the car was going but it did manage to stop very soon after hitting me. The witness can testify to these facts as well. 20.9 No 20.10 No 20.11 On November 22, 2013 I took the bicycle to have it repaired at the Chain Reaction bike shop. Their address is 1451 El Camino Real, Redwood City. 650-366-7130 They had it for a few days. No one other than I has had it since.