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Thus, all contention interrogatories should be written with one or two objec- tives in mind: (1) the answers to conten- tion interrogatories can be used to support a summary judgment or other limit on trial, i.e., to limit the defense to the facts, witnesses and documents set forth in their answers to interrogatories ? ...
The responding party must serve a written response on the requesting party within 30 days after service of the interrogatories, except that a defendant in a suit governed by the Family Code served with a request before the defendant's answer is due need not respond until 50 days after service of the request.
(2) Interrogatories. Each party may serve no more than 25 written interrogatories, excluding interrogatories asking a party only to identify or authenticate specific documents. Each discrete subpart of an interrogatory is considered a separate interrogatory.
Examples of good, specific contention interrogatories include: Do you contend that plaintiff's claim is barred by the provisions of Code of Civil Procedure § 339? Do you contend that plaintiff is the owner of Blackacre?