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
interrogatory responses
What Constitutes a Good Faith Meet-and-Confer Effort?
Before filing a motion to compel discovery responses, the parties must engage in a “reasonable and good faith attempt at an informal resolution of each issue presented by the motion.” CCP §2016.040. What constitutes a good faith meet-and-confer effort depends on a variety of factors. Continue reading
What to Tell Clients When Discovery Starts
Once discovery starts, you’ll need to contact your client to help with responses. Here’s a sample letter to explain what is happening and what you need from your client. Continue reading
Checklist: Procedures for Interrogatories
Keep this checklist handy the next time you’re propounding or responding to interrogatories—whether it’s your first time or you’re so familiar with the procedures that you just might accidentally skip something. Continue reading
12 Grounds for Objecting to Interrogatories
Interrogatories play a key role in litigation: They’re used to gather potential evidence to support a party’s contentions, including facts, witnesses, and writings, or to determine what contentions an opposing party is planning to make. CCP §2030.010(b). But just because they ask doesn’t mean you have to answer. You can object to interrogatories on many grounds. Here’s a list of objections to keep handy when the next batch of interrogatories arrives. Continue reading
Duty to Investigate Before Answering Interrogatories
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
