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How to Write Draft Interrogatories Brainstorm questions to ask the non-party related to the issues in the case. Identify relevant documents, witnesses, or other evidence that will be needed to answer the interrogatories. Draft the interrogatories in written form. Ensure the interrogatories are clear, concise and specific.
Interrogatories need to be served on the other party (CCP §2030.080). If the opposing party has an attorney, they need to be served on their attorney on behalf of the other party. You cannot serve the documents, they must be served by someone who is not a party to the action and over 18 years of age.
Interrogatories may, without leave of court, be served upon the plaintiff after the summons and a copy of the complaint are served upon the defendant, or the complaint is filed, whichever shall first occur, and upon any other party with or after service of the summons and complaint upon that party.
The original form interrogatories and signed proof of service should be retained for your records. If the other party does not respond to your requests, you may use these documents to support a motion to have the court compel responses.
In cases where a party has not propounded pattern interrogatories pursuant to LCR 33, a party may serve no more than 40 interrogatories, including all discrete subparts. (3) Depositions.
First Set of Interrogatories means the Applicant's first set of interrogatories served on Opposer contemporaneously with these Requests.