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You must answer each interrogatory separately and fully in writing under oath, unless you object to it. You must explain why you object. You must sign your answers and objections.
Interrogatories are written questions propounded by one party and required to be answered by another party. Only 30 interrogatories are allowed, including sub-parts, unless the parties agree otherwise or the court grants leave for more. All parties entitled to notice must be served with copies of the interrogatories.
(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 California, if a witness is a non-party i.e., not a party to the action or a party- affiliated witness a deposition subpoena must be served to compel that witness's attendance, testimony, or production of documents and things pursuant to Chapter 6, Nonparty Discovery, of the CDA, Cal. Civ.
Interrogatory subparts are counted as one interrogatory if they are logically or factually subsumed within and necessarily related to the primary question. Safeco of America v. Rawstron, 181 F.R.D. 441, 445 (C.D. Cal.
Language permits a party to serve interrogatories only on other parties.Second, and in any event, Rule 45 does not permit a party to use a subpoena to obtain information from non-parties that is unrelated to the action in which the Rule 45 subpoena is issued.
So, can you refuse to answer interrogatories? The answer is, no, you may not.That answer must either permit inspection of the requested information or object to the production of the information for a specific reason.
The rules of practice require that responses to interrogatories are provided under oath, which in your case, would be taken by a Notary.