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If the court grants leave or the party consents, you can deliver interrogatories to any party in the action and they must be replied to within 21 days of delivery. Answers to interrogatories are delivered in the form of an affidavit, so the party answering the questions swears to the truth of the answers.
The key word is ?unwarranted.? The judge will weigh the amount of annoyance or embarrassment against the relevance of the evidence, and the need for the evidence in the case. You may object if the request would be "unwarranted oppression," also known as an unreasonable burden or expense to comply with.
A party may object to interrogatories when being required to answer would result in ?unwarranted annoyance, embarrassment, or oppression, or undue burden and expense.? (Code Civ. Proc., § 2023.010(c).) 4. Unreasonably cumulative or undue burden and expense.
Interrogatories are often preferable to depositions for identi- fying such things as witnesses, documents, the dates and sub- stance of transactions and conversations,3 since a deponent may easily forget or overlook relevant information when an- swering such questions.
Each supplemental or further response and each amended answer must be identified by the same number or letter and be in the same sequence as the corresponding interrogatory, inspection demand, or admission request, but the text of the interrogatory, demand, or request need not be repeated.