PLAINTIFF‘S RESPONSE(S) TO DEFENDANT HOLT'S INTERROGATORIES AND REQUESTS FOR PRODUCTION TO PLAINTIFF

No. CT-2449-22
Div. V

PLAINTIFF‘S RESPONSE(S) TO DEFENDANT HOLT’S INTERROGATORIES AND REQUESTS FOR PRODUCTION TO PLAINTIFF

1. Comes now Plaintiff, Hwang(Pro Se) for submitting this PLAINTIFF‘S RESPONSE(S) TO DEFENDANT HOLT’S INTERROGATORIES AND REQUESTS FOR PRODUCTION TO PLAINTIFF, and alleges, states, or/and answers the following:

2. Plaintiff respectfully submits his response(s) to this Honorable Court.

3. Plaintiff prays that this Honorable Court award such other relief, at law or in equity, as to which Plaintiff may be justly entitled or the Court may find appropriate/just/proper.

Respectfully submitted,

Hwang

Dated: March 23, 2023

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PLAINTIFF‘S RESPONSE(S) TO DEFENDANT HOLT’S INTERROGATORIES TO PLAINTIFF
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1. PLAINTIFF’S ANSWER TO INTERROGATORY NO. 1:

Name: Hwang

Informal name: Hwang’s former spouse and family-in-law called him as “Pxxxxxn.“

Current address of residence: Plaintiff cannot specify his current address of residence because of the possibility of additional exposure of crimes(felonies).

Plaintiff lives alone right now because of the car accidents.

Plaintiff is self-employed.

Plaintiff cannot organize, as of right now, the addresses of residence for the past ten(10) years because he continued/continues to move again and again because of the car accidents and their related crimes(felonies).

2. PLAINTIFF’S ANSWER TO INTERROGATORY NO. 2:

Those who were at the scene of the car accident (Defendant and her passengers/ reference: police report)

The police officer who was at the scene right after the car accident(xxxxxxxxxx Police Department/ reference: police report)

Medical professionals who were at the xxxxxxx Hospital(reference: medical records)

An attorney at xxxxxx Law Firm

3. PLAINTIFF’S ANSWER TO INTERROGATORY NO. 3:

Medical professionals who were at the xxxxxxx Hospital(reference: medical records)

4. PLAINTIFF’S ANSWER TO INTERROGATORY NO. 4:

Plaintiff didn’t consume such things at all.

5. PLAINTIFF’S ANSWER TO INTERROGATORY NO. 5:

Reference: police report

6. PLAINTIFF’S ANSWER TO INTERROGATORY NO. 6:

Various kinds of sufferings (non-economic and/or economic sufferings)

Reference: medical records

7. PLAINTIFF’S ANSWER TO INTERROGATORY NO. 7:

Reference: medical records

Plaintiff would like to investigate, during the process of discovery, the deposition(s), and/or the trial(s), why he could not have additional medical check-ups and treatments.

8. PLAINTIFF’S ANSWER TO INTERROGATORY NO. 8:

Reference: medical records

9. PLAINTIFF’S ANSWER TO INTERROGATORY NO. 9:

Plaintiff is self-employed.

10. PLAINTIFF’S ANSWER TO INTERROGATORY NO. 10:

Reference: medical records

11. PLAINTIFF’S ANSWER TO INTERROGATORY NO. 11:

Reference: medical records

12. PLAINTIFF’S ANSWER TO INTERROGATORY NO. 12:

Reference: medical records

13. PLAINTIFF’S ANSWER TO INTERROGATORY NO. 13:

Plaintiff filed 4 civil complaints until now because of the car accidents.

14. PLAINTIFF’S ANSWER TO INTERROGATORY NO. 14:

Plaintiff does not have any criminal records.

15. PLAINTIFF’S ANSWER TO INTERROGATORY NO. 15:

Reference: police report

16. PLAINTIFF’S ANSWER TO INTERROGATORY NO. 16:

Reference: police report

17. PLAINTIFF’S ANSWER TO INTERROGATORY NO. 17:

It can depend on the situations or/and circumstances.

18. PLAINTIFF’S ANSWER TO INTERROGATORY NO. 18:

Reference: police report

19. PLAINTIFF’S ANSWER TO INTERROGATORY NO. 19:

Reference: police report

20. PLAINTIFF’S ANSWER TO INTERROGATORY NO. 20:

Plaintiff is self-employed.

The industry of plaintiff’s job: Independent Journalism & Videography

The title of plaintiff’s job: Producer

21. PLAINTIFF’S ANSWER TO INTERROGATORY NO. 21:

Plaintiff graduated from a university in the Republic of Korea(South Korea).

Plaintiff’s academic major was English. His minor was law.

Plaintiff served for the ROK Army for 26 months.

Plaintiff’s military specialty was transportation.

22. PLAINTIFF’S ANSWER TO INTERROGATORY NO. 22:

Reference: medical records

Reference: plaintiff’s other lawsuits/litigations

23. PLAINTIFF’S ANSWER TO INTERROGATORY NO. 23:

Reference: medical records

Reference: plaintiff’s other lawsuits/litigations

24. PLAINTIFF’S ANSWER TO INTERROGATORY NO. 24:

Plaintiff does not use such social media service on the regular basis.

Plaintiff would like to use them when he can, but he could not use them both because of his habits and because of the car accidents.

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PLAINTIFF‘S RESPONSE(S) TO DEFENDANT HOLT’S REQUESTS FOR PRODUCTION TO PLAINTIFF
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1. PLAINTIFF’S RESPONSE TO REQUEST NO. 1:

Reference: police report

2. PLAINTIFF’S RESPONSE TO REQUEST NO. 2:

Reference: medical records

3. PLAINTIFF’S RESPONSE TO REQUEST NO. 3:

Reference: police report

Reference: medical records

Reference: plaintiff’s other lawsuits/litigations

Plaintiff is self-employed.

The industry of plaintiff’s job: Independent Journalism & Videography

The title of plaintiff’s job: Producer

4. PLAINTIFF’S RESPONSE TO REQUEST NO. 4:

Plaintiff is self-employed.

Plaintiff couldn’t/cannot organize such materials/data because of the car accidents and their related crimes(felonies).

5. PLAINTIFF’S RESPONSE TO REQUEST NO. 5:

Reference: police report

Reference: medical records

Reference: plaintiff’s other lawsuits/litigations

6. PLAINTIFF’S RESPONSE TO REQUEST NO. 6:

Reference: police report

Reference: medical records

Reference: plaintiff’s other lawsuits/litigations

7. PLAINTIFF’S RESPONSE TO REQUEST NO. 7:

Plaintiff is a Pro Se litigant.

Plaintiff filed the civil complaint(s) by himself and for himself.

8. PLAINTIFF’S RESPONSE TO REQUEST NO. 8:

Plaintiff is a Pro Se litigant.

Plaintiff filed the civil complaint(s) by himself and for himself.

Plaintiff did not try to contact or/and communicate Defendant(s) about the Lawsuit.

Plaintiff served the copies of the civil complaint and summons.

9. PLAINTIFF’S RESPONSE TO REQUEST NO. 9:

Reference: police report

Reference: medical records

Reference: plaintiff’s other lawsuits/litigations

10. PLAINTIFF’S RESPONSE TO REQUEST NO. 10:

Reference: police report

Reference: medical records

Reference: plaintiff’s other lawsuits/litigations

11. PLAINTIFF’S RESPONSE TO REQUEST NO. 11:

Reference: police report

Reference: medical records

Reference: plaintiff’s other lawsuits/litigations

12. PLAINTIFF’S RESPONSE TO REQUEST NO. 12:

Reference: police report

Reference: medical records

Reference: plaintiff’s other lawsuits/litigations

13. PLAINTIFF’S RESPONSE TO REQUEST NO. 13:

There was no REQUEST NO. 13 in the document.

It seems to be an error by the counsel(s).

14. PLAINTIFF’S RESPONSE TO REQUEST NO. 14:

Reference: police report

Reference: medical records

Reference: plaintiff’s other lawsuits/litigations

15. PLAINTIFF’S RESPONSE TO REQUEST NO. 15:

Reference: police report

Reference: medical records

Reference: plaintiff’s other lawsuits/litigations

16. PLAINTIFF’S RESPONSE TO REQUEST NO. 16:

Reference: police report

Reference: medical records

Reference: plaintiff’s other lawsuits/litigations

17. PLAINTIFF’S RESPONSE TO REQUEST NO. 17:

Reference: police report Reference: medical records

Reference: plaintiff’s other lawsuits/litigations

18. PLAINTIFF’S RESPONSE TO REQUEST NO. 18:

Reference: police report

Reference: medical records

Reference: plaintiff’s other lawsuits/litigations

Plaintiff could not organize, until now, such materials/data because of the car accidents and their related crimes(felonies).

19. PLAINTIFF’S RESPONSE TO REQUEST NO. 19:

Reference: medical records

Reference: plaintiff’s other lawsuits/litigations

Plaintiff could not organize, until now, such materials/data because of the car accidents and their related crimes(felonies).

20. PLAINTIFF’S RESPONSE TO REQUEST NO. 20:

Reference: police report

Reference: medical records

Plaintiff’s automobile insurance company was xxxxx xxxx automobile insurance at the time of the accident.

Plaintiff’s health insurance company was xxxx xxxxx xxxx xxxxx at the time of the accident.

Plaintiff can try to submit additional documents when necessary.

21. PLAINTIFF’S RESPONSE TO REQUEST NO. 21:

Plaintiff is self-employed.

The industry of plaintiff’s job: Independent Journalism & Videography

The title of plaintiff’s job: Producer

22. PLAINTIFF’S RESPONSE TO REQUEST NO. 22:

Reference: PLAINTIFF‘S RESPONSE(S) TO DEFENDANT HOLT’S INTERROGATORIES TO PLAINTIFF

23. PLAINTIFF’S RESPONSE TO REQUEST NO. 23:

Reference: police report

Reference: medical records

Reference: plaintiff’s other lawsuits/litigations

24. PLAINTIFF’S RESPONSE TO REQUEST NO. 24:

Reference: police report

Reference: medical records

Reference: plaintiff’s other lawsuits/litigations

25. PLAINTIFF’S RESPONSE TO REQUEST NO. 25:

The opposing counsel(s)/parties already have them because plaintiff received such documents from them.

Plaintiff did not receive anything from any other indivisual(s).

26. PLAINTIFF’S RESPONSE TO REQUEST NO. 26:

The opposing counsel(s)/parties already have them because Plaintiff received such documents from them.

Plaintiff did not receive anything from any other indivisual(s).

27. PLAINTIFF’S RESPONSE TO REQUEST NO. 27:

Plaintiff’s health insurance company was xxxx xxxxx xxxx xxxxx at the time of the accident.

Plaintiff can try to submit additional documents when necessary.

28. PLAINTIFF’S RESPONSE TO REQUEST NO. 28:

Reference: police report

29. PLAINTIFF’S RESPONSE TO REQUEST NO. 29:

Plaintiff had/has been contacted both by the attorney at xxxxxx Law Firm and/or by the indivisual(s) who seemed to be related to Defendant(s).

There was no serious evaluation of the condition of the property.

Counsel(s) for Defendant(s) can try to contact them mentioned above when necessary.

30. PLAINTIFF’S RESPONSE TO REQUEST NO. 30:

31. PLAINTIFF’S RESPONSE TO REQUEST NO. 31:

32. PLAINTIFF’S RESPONSE TO REQUEST NO. 32:

33. PLAINTIFF’S RESPONSE TO REQUEST NO. 33:

Plaintiff couldn’t/cannot organize such materials/data because of the car accidents and their related crimes(felonies).

Plaintiff can try to submit additional documents when necessary.

34. PLAINTIFF’S RESPONSE TO REQUEST NO. 34:

Reference: medical records

Reference: plaintiff’s other lawsuits/litigations

. [The End]
This is the end of the documents. The total pages are 14 pages.

Written by Mr. Hwang

Published: March 23, 2023