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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?
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.
You should respond to each interrogatory in the order received. Start by retyping each interrogatory and then follow each question with your answer. If an answer comes from information you received from other people, you should write that as part of your response. Your answers must be signed under oath.
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 response shall answer each interrogatory separately and fully in writing under oath, or shall state fully the grounds for refusal to answer any interrogatory. The response shall set forth each interrogatory followed by its answer.