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You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.
Read each question (interrogatory) very carefully. Answer only the question that is asked, and avoid the temptation to over-explain your answer. If the question contains several parts, you may break your answer into parts as well. It is also possible that you might object to the question.
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.
The responding party must serve a written response on the requesting party within 30 days after service of the interrogatories. (b) Content of response. A response must include the party's answers to the interrogatories and may include objections and assertions of privilege as required under these rules.
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.