Q: Unique distinct authentic identity of natural person

A: You can base the inquiry on section 1798.3(a), which defines "personal information" in a way that encompasses the unique and authentic identity of a natural person. This section is part of the California Civil Code, specifically the California Consumer Privacy Act (CCPA), and it is relevant when requesting verifiable personal information.

To ensure the interrogatory is based on a statute that guarantees accurate identity information, you might consider referencing the Health Insurance Portability and Accountability Act (HIPAA) if medical records are involved. HIPAA requires that covered entities protect patient information, which includes ensuring the accuracy and authenticity of such data. Another relevant statute could be the California Confidentiality of Medical Information Act (CMIA), which also emphasizes the protection and accuracy of medical information.

When propounding such an interrogatory, clearly state your request for the verifiable, authentic identity of the individual in question, citing the relevant statutes. For example, you could ask, "Pursuant to section 1798.3(a) of the California Civil Code and applicable provisions of HIPAA and CMIA, please provide all documents and information verifying the unique and authentic identity of the plaintiff as recorded in your hospital's records." This approach ensures that your request is clear, legally grounded, and likely to compel a thorough response.