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(b) Except as provided in Section 2030.070, no party shall, as a matter of right, propound to any other party more than 35 specially prepared interrogatories. If the initial set of interrogatories does not exhaust this limit, the balance may be propounded in subsequent sets.

Contention interrogatories can be characterized as: any question that asks another party to indicate what it contends . . . a question asking another party whether it makes some specified contention . . . a question asking an opposing party to state all facts on which it bases some specified contention . . .

Some of the questions you might ask using interrogatories include: State your insurance information including company, policy number, address, and phone number. Describe the color of the light at the time of the accident (red, green, etc.)

See California Code of Civil Procedure §§2030.030(a)(2) and 2030.060. Their use was usually the first volley in the discovery battle. For years the Courts had found that the Form Interrogatories were objection proof as to form with minor exceptions.

1985), provides examples of four common contention interrogatories: (1) those that begin, Do you contend that . . . ; (2) those that ask for all the facts on which a contention is based, which often begin with Describe in detail . . . ; (3) those that ask a party to take a position and then explain or defend that

An interrogatory is not objectionable because an answer to it involves an opinion or contention that relates to fact or the application of law to fact, or would be based on information obtained or legal theories developed in anticipation of litigation or in preparation for trial.

Interrogatories are lists of questions sent to the other party that s/he must respond to in writing. You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.

How To Write Interrogatories Local Rules. Step one: Read the local rules.Subparts and Compound Questions. Again, you need to head to your local rules and see how they handle compound questions.Tailored Definitions.Tailored Definitions Relating to Documents.Vague Interrogatories Beget Vague Responses.Detail Oriented.

There are two types of interrogatories: form interrogatories and special interrogatories.

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Discovery will also be part of an injury settlement, even if a case does not go to trial. Litigators typically serve them along with interrogatories and document requests in their cases.Personal injury suits are made up of a number of stages. PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT Pursuant to Fed. San Diego County Superior Court. Evidence of the plaintiff's injuries appears in the plaintiff's medical records. After all, the plaintiff filed suit and claims emotional distress. A party propounding interrogatories shall number each set of interrogatories consecutively. Personal injury interrogatories form. The defendant was negligent in the use or maintenance of the property.

San Diego California Plaintiff's Interrogatories to Defendant - Personal Injury

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