Interrogatories

• Author: Robert F. Kane/Donald G. Rez
• Pages: 269-328

Chapter 24

Interrogatories

QUICK VIEW

Definition: Interrogatories are written questions directed to a party requesting that party to provide sworn answers

to the questions.

Scope of Chapter: General principles and techniques about interrogatories; how to propound interrogatories;

how to respond, including both answering and objecting; supplemental and amended answers; motion practice

related to interrogatories; and evidence issues.

Strategies and Tactics:

Propounder: Draft interrogatories that identify the requested information with reasonable particularity.

Respondent: Work with the client to compile the responsive information. To avoid waiving objections to the

interrogatories, timely serve a written response asserting all the objections you want to preserve. If the inter-

rogatories seek confidential information, propose the parties enter into a Confidentiality Agreement, or make a

motion for a protective order.

Statutes and Rules: CCP §§2030.010-2030.410, 2033.710-2033.740; CRC 3.1000, 3.1345.

Related Topics: All Discovery, Ch 20; Production of Documents and Other Things, Ch. 21; Requests for

Admission, Ch 25.

Forms in Digital Access: See digital access for the following forms:

• Form 24:10 Special Interrogatories.

• Form 24:20 Declaration in Support of Additional Interrogatories.

• Form 24:30 Declaration in Support of Additional Discovery with Special Interrogatories [with details re

relevance of interrogatories].

• Form 24:40 Responses to Special Interrogatories.

• Form 24:50 Notice of Motion and Motion to Compel Responses to Special Interrogatories, Requests for

Production, and Form Interrogatories.

• Form 24:60 Notice of Motion to Compel Further Responses to Special Interrogatories, Form Interrogatories,

and Requests for Admission [with ruling by telephone; no appearance required].

• Form 24:70 Points and Authorities in Support of Motion to Compel Further Responses to Special

Interrogatories, Form Interrogatories, and Requests for Admission.

California Pretrial Practice & Forms 24-2

• Form 24:80 Declaration in Support of Motion to Compel Further Response to Special Interrogatories,

Form Interrogatories, and Requests for Admission.

• Form 24:90 Statement of Items in Dispute in Support of Motion to Compel Further Responses to Special

Interrogatories, Form Interrogatories, and Requests for Admission.

• Form 24:100 [Proposed] Order Granting Motion to Compel Further Responses to Special Interrogatories,

Form Interrogatories, and Requests for Admission.

• Form 24:110 Points and Authorities in Opposition to Motion to Compel Further Responses to Special

Interrogatories, Form Interrogatories, and Requests for Admission.

• Form 24:120 Points and Authorities in Opposition to Motion to Compel Further Response to Interrogatories

[with declaration and exhibits].

• Form 24:130 Statement of Items in Dispute in Opposition to Motion to Compel Further Responses.

• Form 24:140 Notice of Motion and Motion for a Protective Order #1.

• Form 24:150 Points and Authorities in Support of Motion for Protective Order #1.

• Form 24:160 Declaration in Support of Motion for a Protective Order #1.

• Form 24:170 Notice of Motion and Motion for Protective Order #2.

• Form 24:180 Points and Authorities in Support of Motion for Protective Order #2.

• Form 24:190 Declaration in Support of Motion for a Protective Order Regarding Excessive Interrogatories #2.

• Form 24:200 [Proposed] Order Granting Motion for Protective Order.

24-3 Interrogatories

TABLE OF CONTENTS

I. OVERVIEW

A. GENERAL RULES AND PRINCIPLES

§24:01 Governing Statute: CCP §§2030.010-2030.410

§24:02 Definition and Scope

§24:03 Advantages

§24:04 Disadvantages

§24:05 Propounded by Parties, on Parties

§24:06 Who Are Parties?

§24:07 Non-Individual Entities

B. FORM AND SPECIAL INTERROGATORIES

§24:20 Official Form Interrogatories and Special Interrogatories

§24:21 Judicial Council Official Form Interrogatories

§24:22 Official Form Interrogatories Are Optional

§24:23 Advantages of Official Form Interrogatories

§24:24 Special Interrogatories: Right to 35

§24:25 Bases for More than 35 Interrogatories

§24:26 Required Supporting Declaration

§24:27 Protective Order Available

II. HOW TO USE INTERROGATORIES

A. GENERAL POINTS

§24:40 Goals and Purposes

§24:41 Using With Depositions

§24:42 Using With Document Requests

§24:43 Using With Requests for Admissions

§24:44 When to Delay Interrogatories

B. TYPES OF INTERROGATORIES

§24:50 Witness Interrogatories

§24:51 Contention Inquiries

§24:52 Should-Have-Done Inquiries

§24:53 Change-of-Heart Inquiries

§24:54 Source-of-Information Interrogatories

§24:55 Damage Inquiries

§24:56 Supplemental Interrogatories

§24:57 Bill of Particulars: Contract and Quasi-Contract Cases

III. PROPOUNDING INTERROGATORIES

A. OFFICIAL FORM INTERROGATORIES

§24:70 Using Form Interrogatories

B. FORMAT OF SPECIAL INTERROGATORIES

§24:80 Caption

§24:81 Title Document

§24:82 Opening Paragraph

§24:83 Footer

§24:84 Numbering

§24:85 Signature

§24:86 Service

C. PRELIMINARY PARTS

§24:100 Instructions Not Permitted

§24:101 Use CAPS for Defined Terms

§24:102 No Subparts or Compound Interrogatories