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Unless otherwise stipulated or ordered by the court, a party may serve on any other party no more than 25 written interrogatories, including all discrete subparts. Leave to serve additional interrogatories may be granted to the extent consistent with Rule 26(b)(1) and (2). (2) Scope.
Make each question complete and self-contained (Code Civ. Proc., § 2030.060(d)). In other words, interrogatories can't refer to a preceding question or make the responding party refer to other documents to understand the question. Don't use subparts or compound, conjunctive, or disjunctive questions.
You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.
(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.
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.
A Form Interrogatory is a list of questions on a court form. You select the questions you want the other side to answer by checking the questions on the form. Use Form Interrogatories ? Family Law (form FL-145) to get basic information from your spouse about issues in your divorce.
Use a Special Interrogatory (sometimes called a Specially Prepared Interrogatory) if you want to write the questions yourself. You use this if you want to ask questions that are specific to your case and are not included on the Form Interrogatory form. A Special Interrogatory doesn't use a specific court form.
Form interrogatories have been created for use in both limited and unlimited cases. Subparts are prohibited in interrogatories in limited cases (cases under $25,000), to ensure that only 35 questions total are asked. For this reason, a form was created specifically for limited civil cases.