Legal Question in Civil Litigation in California
Form Interrogatories served upon opposition included #15.1:"Identify each denial...or affirmative defense...and for each (a) state all facts...(c) itentify all DOCUMENTS..." and #17.1 ...for each response to each request for admission..."(b) state all facts...(d) identify all DOCUMENTS...". Opposition deliniated 90 Request for Admissions and 21 denials with boilerplate objections and vague Responses. To compel Form Interrogatory #s 15.1 & 17.1, is it necessary to include in Seperate Statement a rebuttal to objections & argument to compel for each of the 90 incomplete responses to Admissions and 21 denials, or may a single argument suffice for #15.1 and a single argument to compel Form Interragatory 17.1 suffice. Seperate arguments & rebuttals for each of 90 "admissions" under Form Interrogatory #17.1 may amount to 100s of pages.
1 Answer from Attorneys
15.1 seeks information regarding each denial or affirmative defense in the answer. That should have one reason for further response on the separate statement.
In other words, you have to list the interrogatory verbatim, their response verbatim, and then a statement of reasons of why a further response is required.
17.1 seeks denials of the requests for admissions. Again, you will need your separate statement to have the interrogatory, the text of the response, and one statement of reasons why further response is required.
You are mixing up the further responses to the requests for admission with the further responses to the form interrogatories. You should be meeting and conferring and filing a separate statement along with a motion to compel further responses on the requests for admission.
There are a lot of tricky procedural rules that are too long to list here. You really need an attorney to handle this, or at least provide you legal coaching for a reasonable fee.
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