Interrogatories: Responding to Interrogatories (CA)

by Practical Law Litigation

A Practice Note discussing the process of drafting and serving responses to interrogatories in California unlimited civil cases. This Note outlines the duty to search for responsive information, identifies who must respond to interrogatories, and details the permissible types of responses under the California Code of Civil Procedure. It provides guidance on drafting responses, including the case caption, introduction, answers, objections, signature block, and verification. This Note explains the circumstances under which a responding party may elect to produce documents rather than state an answer. Additionally, it covers serving the response, including preparing the proof of service, and addresses the timing and methods of service. This Note emphasizes the importance of consulting with clients to ensure accurate and complete responses, highlighting the duty to conduct a reasonable investigation to gather information. It also discusses the implications of responses at trial and the rules on supplementing and amending responses. Practical considerations such as general objections, specific objections, and the risks associated with incomplete answers are explored, providing a comprehensive resource for navigating interrogatory responses in California civil litigation.