Drafting special interrogatories is yet another mainstay of litigation practice that’s generally not covered well in law school. Consider this a summary overview to get you started. Format of special interrogatories. Unlike form interrogatories, there’s no judicial council form for special interrogatories. Special interrogatories contain a caption similar to pleadings, which lists the attorney’s contact information, the county where the action has been filed, the parties, the name of the document, and the set number. Immediately below the caption, all special interrogatories must set out (CCP §2030.060(b)): The propounding party; The set number; The responding party; and The time limit to respond to the interrogatories (i.e., 30 days from the date of service pursuant to CCP §2030.010 – CCP §2030.410). In addition to this boilerplate information, make sure that each set of interrogatories is numbered consecutively and separately. CCP…
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