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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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.
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Case No.
Special Interrogatories, Set One
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SPECIAL INTERROGATORIES, SET ONE

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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
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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
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SPECIAL INTERROGATORIES, SET ONE

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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
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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.
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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.
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SPECIAL INTERROGATORIES, SET ONE