Legal Question in Administrative Law in California

Exceeding numeric restriction on interrogatoties

I am a plaintiff in pro per. I am using the interrogatories form DISC-001 and checking all the relevant questions that I want the defendant to answer. The total number of questions checked came to 20. By studing Model Interrogatories by Kevin R. Culhane, I am propounding additional 50 questions to the defendant. Since my total questions exceed the number of specially prepared interrogatories permitted by Section 2030.030 of the Code of Civil Procedure, I prepared a declration for additional discovery. Here are my questions:

1) Can I put sequential numbers on 20 checked questions on DISC-001?

2) What should be the starting number on the set of additional interrogatories?

3) Can I use declration for additional discovery for RFA and request for production of documents?

I appreciate your advice.


Asked on 1/10/08, 4:16 pm

1 Answer from Attorneys
Clayton Lee Russakow, Ryan & Johnson

Re: Exceeding numeric restriction on interrogatoties

You can propound as many of the Judicial Council Form Interrogatories as you want. On your Specially Drafted interrogatories, the numbering is completely independent of the form interrogatories. Just start at number 1 in your first set and go from there. If you propound a second set of special interrogatories, start with number N where N = n +1 and n = the number of special interrogatories in your first set. You get 35 and then you need the Declaration. You also only get 35 RFA's and then you need another Declaration. I suppose you could do a single Declaration addressing both sets and the circumstances warranting the additional discovery, but be sure to serve it all together. Remember, if you have multiple defendants, you get 35 special rogs and 35 RFA's as a matter of right against EACH OF THEM. Plan wisely. Call if you need help.

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Answered on 1/10/08, 4:24 pm


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