Sample special interrogatories for California

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These sample special interrogatories for California is for a California civil case and is intended to be used by a defendant but can be modified for use by a plaintiff. The sample document on which this preview is based is very detailed and is 33 pages long including the declaration for additional discovery and proof of service by mail.

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Sample special interrogatories for California

  1. 1. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Any Defendant Any Street Any Town, CA 55555 714-555-5555 Any Attorney or Defendant Superior Court of the State of California For the County of ________________ Any Plaintiff, Plaintiff, vs. Any Defendant, and DOES 1-5 Defendants. ) ) ) ) ) ) ) ) ) ) Case No. Special Interrogatories, Set One To subscribe to my FREE California weekly legal newsletter visit http://www.legaldocspro.net/newsletter.htm and enter your e-mail address. Be sure to remove this and all other notices before using this document. If you like this sample motion please visit the Facebook page for LegalDocsPro at: http://www.facebook.com/LegalDocsPro and give it a like - 1 - SPECIAL INTERROGATORIES, SET ONE
  2. 2. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 To purchase and download the entire sample document visit: http://www.scribd.com/doc/26010380/Sample-Special-Interrogatories- to-Plaintiff 1PROPOUNDING PARTY: ANY DEFENDANT RESPONDING PARTY: ANY PLAINTIFF SET NO.: ONE TO: PLAINTIFF,_______________________, AND HIS ATTORNEYS OF RECORD: Defendant, ____________________________________________ hereby request that Plaintiff,___________________________, answer the following special interrogatories, separately and fully in writing and under oath, pursuant to Code Of Civil Procedure 2030.010 et seq. Each answer must be as complete and straightforward as the information reasonably available to you permits. If an interrogatory cannot be answered completely, answer it to the extent possible. If you do not have enough personal knowledge to fully answer an interrogatory, say so, but make a reasonable and good faith effort to obtain the information by asking other persons or organizations. INSTRUCTIONS TO THE ANSWERING PARTY 1. In Superior Court actions, an answer or other appropriate response must be given to each interrogatory. 2. As a general rule, within 30 days after your are served with these interrogatories, you must serve your responses on the asking party and serve copies of your responses on all other parties to the action who have appeared. See Code of Civil Procedure § 2030.010 et. seq. 3. Each answer must be as complete and straightforward as the information - 2 - SPECIAL INTERROGATORIES, SET ONE
  3. 3. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 reasonably available to you permits. If an interrogatory cannot be answered completely, answer it to the extent possible. 4. If you do not have personal knowledge to fully answer an interrogatory, say so, but make a reasonable and good faith effort to get the information by asking the other persons or organizations, unless the information is equally available to the asking party. 5. Whenever an interrogatory may be answered by referring to a document, the document may be attached as an exhibit to the response and referred to in the response. If the document has more than one page, refer to the page and section where the answer to the interrogatory can be found. 6. Whenever an address and telephone number for the same person are requested in more than one interrogatory, you are required to furnish them in answering only the first interrogatory asking for that information. 7. Your answers to these interrogatories must be verified, dated, and signed. DEFINITIONS 1. "YOU" or "YOU OR ANYONE ACTING ON YOUR BEHALF" means you, the Plaintiff,____________________. your agents, your employees, your insurance companies, their agents, their employees, your attorneys, your accountants, your investigators, and anyone else acting on your behalf. 2. "YOUR" or "YOURSELF" means ______________________, your agents, your employees, your insurance companies, their agents, their employees, your attorneys, your accountants, your investigators, and anyone else acting on your behalf. 3. "DOCUMENT" means a writing, as defined in Evidence Code 250, and includes the original or a copy of handwriting, type-writing, printing, photostating, photographing, and every - 3 - SPECIAL INTERROGATORIES, SET ONE
  4. 4. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 other means of recording upon any tangible thing and form of communicating or representation, including letters, words, pictures, sounds, or symbols, or combinations of them. 4. "ADDRESS" means the street address, including, the city, state, and zip code. 5. "FULLY IDENTIFY" means in relation to persons to state the full name, telephone number and last known address, including city, state and zip code; in relation to documents, "FULLY IDENTIFY" means to provide the name of the document, date of the document, and the type of document. 6. "PERSON" includes a natural person, firm, association, organization, partnership, business, trust, limited liability company, corporation, or public entity. INSTRUCTIONS FOR THESE SPECIAL INTERROGATORIES This set of special interrogatories has 195 questions, there are 3 questions for each paragraph of the complaint, in this example the complaint has 65 paragraphs. If the complaint in your case has less paragraphs then remove some of the special interrogatories, if it has more then add more special interrogatories based on the ones here. Feel free to add your own special questions if you want. Just be sure that they are relevant to the case. Otherwise the other party will object to them. SPECIAL INTERROGATORIES SPECIAL INTERROGATORY NO. 1: State all facts which support the allegations contained in paragraph 1 of YOUR - 4 - SPECIAL INTERROGATORIES, SET ONE
  5. 5. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Complaint. SPECIAL INTERROGATORY NO. 2: FULLY IDENTIFY all witnesses, including address and telephone number, having personal knowledge of YOUR response to Interrogatory Number 1. SPECIAL INTERROGATORY NO. 3: FULLY IDENTIFY all DOCUMENTS in support of YOUR response to Interrogatory Number 1. - 5 - SPECIAL INTERROGATORIES, SET ONE
  6. 6. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Complaint. SPECIAL INTERROGATORY NO. 2: FULLY IDENTIFY all witnesses, including address and telephone number, having personal knowledge of YOUR response to Interrogatory Number 1. SPECIAL INTERROGATORY NO. 3: FULLY IDENTIFY all DOCUMENTS in support of YOUR response to Interrogatory Number 1. - 5 - SPECIAL INTERROGATORIES, SET ONE

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