California Interrogatories and Requests for Production - Personal Injury

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US-PI-0310
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Description

This form is a sample set of interrogatories and requests for production propounded to defendant by the plaintiff in a personal injury action.

How to fill out Interrogatories And Requests For Production - Personal Injury?

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FAQ

You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.

(a) A defendant may propound interrogatories to a party to the action without leave of court at any time. (b) A plaintiff may propound interrogatories to a party without leave of court at any time that is 10 days after the service of the summons on, or appearance by, that party, whichever occurs first.

In a limited civil case (cases less than $25,000) you may ask each party only 35 discovery questions total, whether they are form interrogatories, special interrogatories, requests for admission, or requests for production of documents.

These are typically requests that are not relevant, unduly burdensome, broad, vague, privileged. or protected by the work product doctrine.

(b) Except as provided in Section 2030.070, no party shall, as a matter of right, propound to any other party more than 35 specially prepared interrogatories. If the initial set of interrogatories does not exhaust this limit, the balance may be propounded in subsequent sets.

Rule 33(a), Federal Rules of Civil Procedure, restricts to 25 (including all discrete subparts) the number of interrogatories a party may serve on any other party. Leave of court, which is not routinely given absent stipulation, is required to serve more than 25 interrogatories cumulatively.

If your case is an unlimited civil case (over $25,000) you may ask up to 35 special interrogatories, but may ask more with a declaration explaining the need for additional requests and a statement that the request is not done for an improper purpose.

Interrogatories, which are written questions about things that are relevant or important to the case. (NRCP 33; JCRCP 33) Requests for production of documents or things, which are written requests that demand the other side provide particular documents or items. (NRCP 34; JCRCP 34.)

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California Interrogatories and Requests for Production - Personal Injury