Use this Cheat Sheet to make sure you are complying with all the statewide rules of civil procedure applicable to interrogatories in California Superior Court. For more detailed information, including local rules, see the California Superior Court SmartRules Interrogatories and Response to Interrogatories Guides and Codes, Courts and Forms coverage for California.
Propoounding and Responding
A defendant may propound written interrogatories at any time. CCP § 2030.020(a).
A plaintiff may propound interrogatories at any time that is ten (10) days after the service of the summons on, or appearance by, that party. CCP § 2030.020(b).
The party propounding interrogatories must serve the party to whom they are directed and all other parties. CCP § 2030.080.
Service may be made by fax on written agreement of the parties. CRC 2.306(a).
Responses to interrogatories are due within thirty (30) days if the interrogatories were personally served, thirty-five (35) days if the interrogatories were served by mail, and thirty (30) days plus two (2) court days if the interrogatories were served by express mail or facsimile or electronically. CCP § 2030.260; CCP § 1013; CRC 2060(b)(2). CRC 2.260(d).
The propounding party must number each set consecutively. In the first paragraph immediately below the title of the case, there must appear the identity of the propounding party, the set number, and the identity of the responding party. Each interrogatory must be separately set forth and identified by number or letter. CCP § 2030.060.
Each interrogatory must be complete. No preface or instruction may be included unless it has been approved under the CCP. Any term specially defined must be typed in capital letters. No special interrogatory may contain subparts, or a compound, conjunctive, or disjunctive question. CCP § 2030.060(d).
An interrogatory may relate to whether another party is making a certain contention, or to the facts, witnesses, and writings on which a contention is based. CCP § 2030.010(b).
An interrogatory may not impose a duty to supplement an answer with later acquired information. CCP § 2030.060(g).
A party may propound a supplemental interrogatory to elicit later acquired information bearing on all answers previously made by any party twice prior to the initial setting of a trial date, and once after the initial setting of a trial date. CCP § 2030.070. Supplemental interrogatories must include, immediately below the title of the case, the identity of the propounding and responding party, the set number and identification of the discovery as supplemental interrogatories. CRC 331(a). CRC 3.1000(a).
A party may propound 35 special interrogatories and any additional number of official form interrogatories. Unless the propounding party has made the required declaration, the responding party need only respond to the first 35 special interrogatories, if the responding party states an objection on the ground that the limit has been exceeded. CCP § 2030.030.