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Unlike form interrogatories that focus on common questions, special interrogatories concentrate on specific questions that help obtain specific information about the case. The party must craft specific questions to establish a point that the other party must prove or disprove.
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?
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.
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 ? ...
[(1)] Where any party fails to comply with any order to answer interrogatories, or for discovery or inspection of documents, he shall, if a plaintiff, be liable to have his suit dismissed for want of prosecution, and, if a defendant, to have his defence, if any struck out, and to be placed in the same position as if he ...