Discovery Interrogatories from Plaintiff to Defendant with Production Requests - California 2026

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  1. Click ‘Get Form’ to open it in the editor.
  2. Begin by entering the name and address of the Petitioner/Plaintiff at the top of the form. Ensure all contact information is accurate.
  3. In the section labeled 'INTERROGATORY NO. 1', provide your full name, social security number, date of birth, residence address, and telephone number as requested.
  4. Continue through each interrogatory, filling in detailed responses. For example, for 'INTERROGATORY NO. 2', attach copies of your income tax returns and W-2 forms for the past three years.
  5. Make sure to answer each interrogatory separately and under oath, as required by California Rules. Review your answers for completeness before submission.
  6. Finally, sign and date the document at the end where indicated, ensuring that you also complete the Certificate of Service section to confirm delivery to the Defendant.

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Interrogatories, which are written questions about things that are relevant or important to the case. (NRCP 33; JCRCP 33) Requests for production of documents or things, which are written requests that demand the other side provide particular documents or items. (NRCP 34; JCRCP 34.)
Unlike interrogatories Requests to Produce are not limited in number. Upon receipt from the opposing party your business lawyer working with you will assess whether any requests are objectionable and what should be produced. These production requests are regularly used in lawsuits.
Requests for admission are not. Furthermore, interrogatories are questions, but theyre phrased as statements to be elaborated upon. The same is not true of requests for admissions. Requests for admission are short, direct questions and their answers can either admit or deny the opinions of fact.
Interrogatories allow the parties to ask who, what, when, where and why questions, making them a good method for obtaining new information in a case. There are two types of interrogatories: form interrogatories and special interrogatories.
In civil procedure , an interrogatory is a list of written questions one party sends to another as part of the discovery process.

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If your case is an unlimited civil case (over $35,000) you may ask up to 35 special interrogatories, but may ask more with a declaration explaining the need for additional requests and a statement that the request is not done for an improper purpose.
Timeframe for discovery If you are the plaintiff, you can begin discovery 10 days after you serve the first papers in the case or anytime after the defendant files a response. If you are the defendant, you may begin discovery as soon as the case is filed.
Requests for Production or Demands for Inspection require you to produce documents for copying or in some cases actual items for inspection. Responding to the request has 2 parts: State if you can comply with the request (all of it or some of it) or give the reason why you cant comply.

request for production of documents california pdf