It’s not required that a party amend interrogatory responses to reflect information the party got after responding, but there are situations in which a party may want to do just that. Continue reading
Before you answer interrogatories, you have a duty to investigate. But what does that mean and how far do you have to go? Continue reading
Interrogatories are the discovery workhorse, with at least six major strengths. Consider the following benefits of propounding interrogatories as you plan discovery for your case. Continue reading
A party served with interrogatories under CCP §§2030.010–2030.410 has to respond by answering, producing writings, or objecting. And each answer has to be as “complete and straightforward as the information reasonably available to the responding party permits.” CCP §2030.220(a). Most often, this process is fairly straightforward. But there are at least three situations when responding to interrogatories may present a problem. Here’s how to skillfully handle them. Continue reading
So, you’ve been hit with interrogatories. Before you start working on responses, review these 6 points. Continue reading
Interrogatories can be a very powerful discovery tool. With interrogatories, you get to ask questions of adverse parties and then use their answers against them at trial. Don’t miss out on this opportunity by bungling the timing of your interrogatories. Continue reading
Often you can use more than one discovery method to get the same facts or evidence. You can take a pick-and-choose approach to your methodology, or better yet, use a coordinated approach that aims multiple discovery methods at the same evidence. Continue reading
Many attorneys mistakenly believe that answers to interrogatories and requests for admission are automatically in evidence after they’re lodged with the court. Not so! First, you’ve got to formally introduce them into evidence.
When drafting special interrogatories, you apply the same basic principles as all legal documents: strive for clarity and brevity, choose language carefully, and avoid vague descriptions. But there are also some special statutory requirements and drafting considerations to keep in mind.
When planning your discovery, you need to know all the key numbers, i.e., the numerical limitations on the various discovery methods. Here’s a handy overview so you will know how much is too much under California’s discovery statutes.