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Unless your written response includes only objections without any factual assertions, it must be verified. This means it must include a statement under the penalty of perjury that your response is true and correct. (CCP § 2031.250).
These objections must be valid and you should note them in your response along with the questions that you are answering. If the other side does not think that your objection is valid, s/he may be able to file a motion to compel, which basically asks the judge to force you to answer the interrogatories.
As the party resisting discovery by objecting to an interrogatory, you have the burden to explain why your objections are proper. To satisfy this burden, you should state your objection with specificity. This means giving specific facts, statutes, or judicial precedent supporting your position.
Your answers to the interrogatories should usually be short, clear, and direct and should answer only the question that is being asked. This is not the time to set out your entire case or defense to the other side. Take the time to make sure your answers are correct and truthful.
Make a List of Questions Brainstorm questions to include in your interrogatories. Identify questions that are relevant to the issues in the case. Consider if the questions are legally permissible. Make sure the questions are direct, specific, and clear. Decide if the questions will help you gain any necessary information.
Responses to interrogatories must be truthful and complete (and are made under oath); and. There may be limits on how many interrogatories are allowable in your jurisdiction.
This letter is often called a good faith letter. And it is needed under many courts' rules before you can file a motion to compel discovery if the other party ignores your requests or provides evasive responses or move for sanctions if your opponent refuses to comply with the court's discovery order.
If you are unable to answer a specific question because you don't know or don't have access to the appropriate information, you must indicate the reasons. You may refer to a previous response when responding to an interrogatory providing the previous response sufficiently answers the later interrogatory.