Responses to special interrogatories in California are the topic of this blog post.
The statutes governing special interrogatories in California are found in Code of Civil Procedure sections 2030.010, et seq.
Any responses to special interrogatories in California must be verified, and must be served on the requesting party within thirty (30) days after service of the special interrogatories if they were personally served, or within thirty five (35) days if the special interrogatories were served by mail. Note that these time limits do NOT apply to unlawful detainer actions which are five (5) days if the requests were personally served or ten (10) days if the requests were served by mail.
Code of Civil Procedure § 2033.210 states that,
“(a) The party to whom interrogatories have been propounded shall respond in writing under oath separately to each interrogatory by any of the following:
(1) An answer containing the information sought to be discovered.
(2) An exercise of the party’s option to produce writings.
(3) An objection to the particular interrogatory.
(b) In the first paragraph of the response immediately below the title of the case, there shall appear the identity of the responding party, the set number, and the identity of the propounding party.
(c) Each answer, exercise of option, or objection in the response shall bear the same identifying number or letter and be in the same sequence as the corresponding interrogatory, but the text of that interrogatory need not be repeated.”
Code of Civil Procedure § 2030.220 states that,
“(a) Each answer in a response to interrogatories shall be as complete and straightforward as the information reasonably available to the responding party permits.
(b) If an interrogatory cannot be answered completely, it shall be answered to the extent possible.
(c) If the responding party does not have personal knowledge sufficient to respond fully to an interrogatory, that party shall so state, but shall make a reasonable and good faith effort to obtain the information by inquiry to other natural persons or organizations, except where the information is equally available to the propounding party.”
There are certain format restrictions on special interrogatories. No special interrogatory may contain subparts, or a compound, conjunctive or disjunctive question. See Code of Civil Procedure § 2030.060. This means that a special interrogatory cannot contain part a, b, c, etc., nor can it contain a question with more than one part, and it cannot contain the word “and” which is conjunctive, it also cannot contain the word “or” which is disjunctive.
While I do not recommend getting too “nitpicky” with objections if a special interrogatory for example contains part a, b, c, etc., in my personal opinion that is sufficient grounds for objecting on that basis in the responses to special interrogatories in California .
Any objections in responses to special interrogatories in California should clearly set forth the specific ground for the objection, and if only part of the special interrogatory is objectionable, the remainder of the special interrogatory must be answered. See Code of Civil Procedure § 2030.240.
Attorneys or parties in California who wish to view a portion of 16 page sample responses to special interrogatories containing brief instructions, sample objections, a verification and proof of service by mail sold by the author can see below.
Attorneys or parties in California that would like more information on a sample California discovery litigation document package containing over 35 sample documents including sample responses to special interrogatories sold by the author can use the link shown below.
The author of this log post, Stan Burman, is a freelance paralegal who has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents for sale.
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Please note that the author of this blog post, Stan Burman is NOT an attorney and as such is unable to provide any specific legal advice. The author is NOT engaged in providing any legal, financial, or other professional services, and any information contained in this blog post is NOT intended to constitute legal advice.
The materials and information contained in this blog post have been prepared by Stan Burman for informational purposes only and are not legal advice. Transmission of the information contained in this blog post is not intended to create, and receipt does not constitute, any business relationship between the author and any readers. Readers should not act upon this information without seeking professional counsel.