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If you are unable to answer an interrogatory because it is too vague, ambiguous, or somehow objectionable, you can state an objection and the reason for your objection. You must then answer to the extent the interrogatory is not objectionable.
You may object if the request is asking for your analysis, strategy, or thinking about the case. A discovery request can ask what evidence the person knows, but cannot ask what a person thinks the evidence means. Sometimes called ?attorney work product,? and this objection applies equally to self-represented litigants.
You have 30 days after the form or special interrogatories were served to you (35 days if served by mail from within California) to serve your responses to the interrogatories. Sometimes, rather than answering the interrogatory, you may wish to object to the request on legal grounds.
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.
You have 30 days to respond to Form Interrogatories. If you were served by mail, you typically have 35 days from the date of mailing to respond.
The Special Interrogatories you received should have a list of numbered questions. You need to respond to each question in the same order on your response template. On your template, each question, write ?Response to Interrogatory number? followed by the number of the question.
The Interrogatory Is Vague, Overly Broad, and Unduly Burdensome. In some cases, the plaintiff may object because the claim is too broad and not directly related to uncovering evidence. This might fly, as long as they can explain why.
The grounds for objecting to an interrogatory must be stated with specificity. Any ground not stated in a timely objection is waived unless the court, for good cause, excuses the failure. (5) Signature. The person who makes the answers must sign them, and the attorney who objects must sign any objections.