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Except as otherwise provided by R. -1(b), the number of interrogatories or of sets of interrogatories to be served is not limited except as required to protect the party from annoyance, expense, embarrassment, or oppression.
Interrogatories: Interrogatories are now limited to 25, including subparts, unless the court orders otherwise by new Rule 202.20. The CPLR does not contain a limitation. Depositions: Among other changes, under new Rule 202.20-b, depositions will be limited to seven hours per deponent.
Rule 202.70. 11-a - Interrogatories (a) Interrogatories are limited to 25 in number, including subparts, unless another limit is specified in the preliminary conference order. This limit applies to consolidated actions as well.
(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.
Some plaintiffs have argued that the requirements for § 3294(b) can be satisfied when a managerial employee with knowledge of the allegations also verifies discovery responses as an officer or agent of the company. California Code of Civil Procedure provides that only an officer or agent may verify Page 2 a
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).
Responses to interrogatories must be verified unless the responding party is not the only party who knows the answer to the question posed and/or if the information is available from another source.
2030.020 Timing For Serving Interrogatories. (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.
Your answers to these interrogatories must be verified, dated, and signed. You may wish to use the following form at the end of your answers: You may insert your own definition of INCIDENT in Section 4, but only where the action arises from a course of conduct or a series of events occurring over a period of time.
The motion to compel further responses has to be brought within 45 days of service of the response. (C.C.P.