Loretha Jones v. Sony Pictures Entertainment, Inc.

,
Anabell Montenegro
TM4168

SUMMARY OF PLAINTIFF’S RESPONSES TO FORM INTERROGATORIES, SET ONE

Plaintiff’s responses were verified by the Plaintiff and

served via US mail on February 4, 2014.

BACKGROUND:

Plaintiff was born on February 3, 1959 in New York. Her

California Driver’s License No. is A7618268.

From December of 1996 through January of 2011, she lived at

2055 Mount Olympus Drive, Los Angeles, California 90046. From
March 2011 to the present, she has been living at 1100 Alta Loma
Road, West Hollywood, California 90069.

She is a graduate of City College of New York and New York

University School of Law where she obtained her Juris Doctorate
Degree in 1984.

EMPLOYMENT

As of January of 2008, she has been working as the President

of Original Programming for BET Networks, 10625 Santa Monica
Boulevard, Suite 200, Los Angeles, California. She was not
working at the time of the incident and she is not attributing
any loss of income or earnings capacity as a result of the
incident.

INSURANCE

At the time of the incident she had medical insurance

through United Health Care. However, Plaintiff now has a new
insurance policy and does not have readily available the
insurance information from her prior insurance carrier.

PROPERTY DAMAGE

1
 At the present time, she is not contending that she has
sustained any property damage and/or damage to her vehicle.

INJURIES SUSTAINED AND TREATMENT RECEIVED

As a result of the incident, she contends that she sustained

an undescribed injury to her arms, hands, knees and neck. Though
she still has some tingling sensations in her right fingers, the
pain complaint that she has are basically subsiding.

She has treated with the following Healthcare Providers:

1. Dr. Stephen Jacobs, 436 North Bedford Drive, Suite 214,

Beverly Hills, California 90210 (310) 271-2328.

2. Dr. Katrina Vlachos, 13160 Mindanao Way, Suite 300, Marina

Del Rey, California 90292 (310) 574-0400.

3. Dr. Steven Tan, 9730 Wilshire Boulevard, Suite 102, Beverly

Hills, California 90212 (310) 276-3888.

4. Paula Gelbart at Core Conditioning, 12930 Ventura Boulevard,

Suite 226 A, Studio City, California 91604.

5. Dr. Nancy Livingston, 1157 South Robinson Boulevard, Los

Angeles, California 90035 (310) 274-1244.

She explains generally that the above-referenced Healthcare

Providers are Internists and acupuncturists, and physical
therapists. Though it isn’t clear, it is apparent that she began
treatment with Dr. Jacobs and Dr. Vlachos approximately 3 to 4
weeks following the incident. She commenced physical therapy on
November 12, 2011 and again on January 2, 2012 and she is still
receiving physical therapy at the present time.

She explained also in a general fashion that Dr. Vlachos and

Dr. Tan have prescribed to her Flexiril and Celebrex. Other than
the above-referenced Healthcare Providers, there are no other
medical services that she received as a result of the incident.

She does not know the amount of her medical bills and she
does not know if any Healthcare Provider has told her that future
or additional treatment for her injuries will required.

INVESTIGATION

2
 The only witness that she knows of is Cleo Smith 1100 Alta
Loma Road, West Hollywood, California 90069, phone number (310)
855-8049. (It is apparent that Cleo Smith resides with the
Plaintiff.)

Plaintiff contends that the defendant violated Vehicle Code

Sections 22350 and 21703.

PLAINTIFF’S CONTENTIONS REGARDING DENIALS OF REQUESTS FOR

ADMISSION

Plaintiff contends that she is not responsible for the

accident and contends that the defendant is responsible because
Plaintiff was a rear seat passenger in a vehicle that was struck
from behind. As a result of the incident, she injured her arms,
hands, knees and neck. Though she does not know the amount of
her medicals, she contends that they are in excess of $10,000.

SGS/db
SumPlf Resp RFA.1 2.6.14