How have courts interpreted the privilege against self-incrimination in a personal injury case?

On the main issue of the availability of the privilege, the court relied upon the Newson language and that from County of S.F. already quoted above, adding, "[a]pplying the principle just stated, it was held that a plaintiff suing to recover [137 Cal.App.3d 559] damages for income lost as a result of injury from defendant's negligence could not assert the privilege against self-incrimination as to questions pertaining to the filing of income tax returns (Newson v. City of Oakland (1974) 37 Cal.App.3d 1050, 1055-1057 [112 Cal.Rptr. 890] ). [Fn. omitted.]" (Id. at p. 829, 134 Cal.Rptr. 130.)