Discovery – Special Interrogatories

While not quite as cost-effective as Form Interrogatories, Special Interrogatories  are another very effective and inexpensive discovery device which can be quite effective.

Special Interrogatories are drafted by the attorney or party.  These are questions that must be relevant to the subject matter and must not seek privilege information.

Special interrogatories are subject to a 35-question limit.  Questions must not have sub-parts and must be totally self-contained and not refer to any earlier question.

Special Interrogatories:

  • are served on a party
  • are subject to a 35-question limit unless accompanied by a declaration regarding the necessity of additional questions over the 35 allowable
  • require 30 days be allowed for response
  • are cost-effective requiring only staff or attorney time to draft and postage

Additional rules and requirements can be found in the California Code of Civil Procedure.


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