Legal Question in Civil Litigation in California

There is no standard form for this. You will have to prepare the responses from scratch.

Place the caption at the top of the page. Title it "Defendant's Responses to Special Interrogatories (Set No. One)." Number each response to correspond with the interrogatory number. Answer as thoroughly as possible. Then sign at the bottom, attach a signed verification under penalty of perjury. Also, have a friend or relative who is not a party execute (sign) a proof of service and have that person mail the original responses along with the proof of service to the attorney who propounded the interrogatories. Keep a copy for your records. All of this must be done within 35 days of the date that the interrogatories were mailed to you as evidenced by the date on the proof of service attached to the interrogatories.

The format is fairly simple: You must format a caption page that looks basically like the first page of the Special Interrogatories you received, only in the upper left corner you put your information, instead of the information for the person who sent them, and instead of saying "Special Interrogatories" you will call it "Responses to Special Interrogatories." Then, where the definitions and instructions (if any) start on the Special Interrogatories, you start with any objections that you have to the entire set of Special Interrogatories. Bear in mind, however, that any objections you state must be objections allowed under the law of civil discovery. You can't just object because you don't like them. Once you have stated any general objections you have, if any are merited under the law, then you start typing up answers to the questions, numbering them the same as the questions are numbered. If there are legally recognized objections to specific questions you also state them there. If the objections are for reasons that allow you not to answer a particular question, such as it ask you what you discussed with a lawyer, then you only state the objection and do not answer. Then you must sign at the bottom and include a verification under penalty of perjury that your answers are true and correct.