Responding to special interrogatories in California is the topic of this blog post.
This blog post will discuss responding to special interrogatories in California. When responding to special interrogatories in California you must be sure to properly verify your responses.
You must also serve your responses 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.
The specific California statutes that govern the use of special interrogatories in California are found in Code of Civil Procedure sections 2030.010, et seq.
Code of Civil Procedure § 2030.210 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.”
California law imposes certain very specific format restrictions on special interrogatories. One important restriction is that California law states that 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 more than sufficient grounds for objecting on that basis in your response to that particular interrogatory or interrogatories.
You must also make sure that any of your responses to a specific special interrogatory that contain any objections very clearly set forth the specific ground for your objection, and if only part of the special interrogatory is objectionable you should answer the remainder of the special interrogatory. See Code of Civil Procedure § 2030.240.
Sample responses to special interrogatories in California for sale.
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.
Sample Responses to Special Interrogatories for California by Stan Burman on Scribd
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DISCLAIMER:
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.