Educational guide
California Civil Special Interrogatories: Request and Response Checklist
A practical general-information checklist for writing or responding to specially prepared interrogatories in a California civil case, based on official California Courts guidance. It is not individualized legal advice, a discovery strategy or a deadline calculation.
- Use special interrogatories when the information needed is not covered well by the standard form interrogatories. California Courts describes them as written questions drafted for the specific case.
- Write each interrogatory as a separate, numbered question using clear language. Avoid compound questions, unnecessary definitions and instructions that make a question difficult to understand or answer.
- Confirm the case type and applicable numerical limits before preparing a set. California Courts says an unlimited civil case generally permits up to 35 special interrogatories without a declaration explaining why more are needed, while limited civil cases have a combined discovery limit.
- Complete the case caption and identify the asking party, answering party and set number. Keep the signed original and an exact copy of every set and attachment.
- Serve the questions using the current California Courts instructions. Written discovery is ordinarily served on every attorney or self-represented party rather than filed with the court, and the person who serves it must meet the applicable nonparty requirements.
- If responding, calendar the deadline from the actual service method and date. California Courts says a response is generally due 30 days after personal service and typically 35 days after mailing within California, but other methods, orders and case types can change the calculation.
- Answer every interrogatory separately, fully and truthfully with information reasonably available. A substantive response must be verified under oath; an objection should identify a legally supportable basis, and qualified help is important when privilege, privacy, burden or scope is disputed.
- Have a qualified nonparty adult serve the signed response and keep the verification and proof of service with the response. Missing or inadequate answers can lead to a motion to compel and possible sanctions, so use the official pages below for current procedure.
Official resources
This guide provides general information only and is not legal or medical advice. Rules and individual circumstances differ. In an emergency, call 911.