2030.010. (a) Any party may obtain discovery within the scope
delimited by Chapters 2 (commencing with Section 2017.010) and 3
(commencing with Section 2017.710), and subject to the restrictions
set forth in Chapter 5 (commencing with Section 2019.010), by
propounding to any other party to the action written interrogatories
to be answered under oath.
(b) An interrogatory may relate to whether another party is making
a certain contention, or to the facts, witnesses, and writings on
which a contention is based. An interrogatory is not objectionable
because an answer to it involves an opinion or contention that
relates to fact or the application of law to fact, or would be based
on information obtained or legal theories developed in anticipation
of litigation or in preparation for trial.
2030.020. (a) A defendant may propound interrogatories to a party
to the action without leave of court at any time.
(b) A plaintiff may propound interrogatories to a party without
leave of court at any time that is 10 days after the service of the
summons on, or appearance by, that party, whichever occurs first.
(c) Notwithstanding subdivision (b), in an unlawful detainer
action or other proceeding under Chapter 4 (commencing with Section
1159) of Title 3 of Part 3, a plaintiff may propound interrogatories
to a party without leave of court at any time that is five days after
service of the summons on, or appearance by, that party, whichever
occurs first.
(d) Notwithstanding subdivisions (b) and (c), on motion with or
without notice, the court, for good cause shown, may grant leave to a
plaintiff to propound interrogatories at an earlier time.
2030.030. (a) A party may propound to another party either or both
of the following:
(1) Thirty-five specially prepared interrogatories that are
relevant to the subject matter of the pending action.
(2) Any additional number of official form interrogatories, as
described in Chapter 17 (commencing with Section 2033.710), that are
relevant to the subject matter of the pending action.
(b) Except as provided in Section 2030.070, no party shall, as a
matter of right, propound to any other party more than 35 specially
prepared interrogatories. If the initial set of interrogatories does
not exhaust this limit, the balance may be propounded in subsequent
sets.
(c) Unless a declaration as described in Section 2030.050 has been
made, a party need only respond to the first 35 specially prepared
interrogatories served, if that party states an objection to the
balance, under Section 2030.240, on the ground that the limit has
been exceeded.
2030.040. (a) Subject to the right of the responding party to seek
a protective order under Section 2030.090, any party who attaches a
supporting declaration as described in Section 2030.050 may propound
a greater number of specially prepared interrogatories to another
party if this greater number is warranted because of any of the
following:
(1) The complexity or the quantity of the existing and potential
issues in the particular case.
(2) The financial burden on a party entailed in conducting the
discovery by oral deposition.
(3) The expedience of using this method of discovery to provide to
the responding party the opportunity to conduct an inquiry,
investigation, or search of files or records to supply the
information sought.
(b) If the responding party seeks a protective order on the ground
that the number of specially prepared interrogatories is
unwarranted, the propounding party shall have the burden of
justifying the number of these interrogatories.
2030.050. Any party who is propounding or has propounded more than
35 specially prepared interrogatories to any other party shall attach
to each set of those interrogatories a declaration containing
substantially the following:
DECLARATION FOR ADDITIONAL DISCOVERY
I, __________, declare:
1. I am (a party to this action or proceeding appearing in propria
persona) (presently the attorney for __________, a party to this
action or proceeding).
2. I am propounding to __________ the attached set of
interrogatories.
3. This set of interrogatories will cause the total number of
specially prepared interrogatories propounded to the party to whom
they are directed to exceed the number of specially prepared
interrogatories permitted by Section 2030.030 of the Code of Civil
Procedure.
4. I have previously propounded a total of __________
interrogatories to this party, of which __________ interrogatories
were not official form interrogatories.
5. This set of interrogatories contains a total of __________
specially prepared interrogatories.
6. I am familiar with the issues and the previous discovery
conducted by all of the parties in the case.
7. I have personally examined each of the questions in this set of
interrogatories.
8. This number of questions is warranted under Section 2030.040 of
the Code of Civil Procedure because __________. (Here state each
factor described in Section 2030.040 that is relied on, as well as
the reasons why any factor relied on is applicable to the instant
lawsuit.)
9. None of the questions in this set of interrogatories is being
propounded for any improper purpose, such as to harass the party, or
the attorney for the party, to whom it is directed, or to cause
unnecessary delay or needless increase in the cost of litigation.
I declare under penalty of perjury under the laws of California
that the foregoing is true and correct, and that this declaration was
executed on __________.
__________________________________________________
(Signature)
Attorney for______________________________________
2030.060. (a) A party propounding interrogatories shall number each
set of interrogatories consecutively.
(b) In the first paragraph immediately below the title of the
case, there shall appear the identity of the propounding party, the
set number, and the identity of the responding party.
(c) Each interrogatory in a set shall be separately set forth and
identified by number or letter.
(d) Each interrogatory shall be full and complete in and of
itself. No preface or instruction shall be included with a set of
interrogatories unless it has been approved under Chapter 17
(commencing with Section 2033.710).
(e) Any term specially defined in a set of interrogatories shall
be typed with all letters capitalized wherever that term appears.
(f) No specially prepared interrogatory shall contain subparts, or
a compound, conjunctive, or disjunctive question.
(g) An interrogatory may not be made a continuing one so as to
impose on the party responding to it a duty to supplement an answer
to it that was initially correct and complete with later acquired
information.
2030.070. (a) In addition to the number of interrogatories
permitted by Sections 2030.030 and 2030.040, a party may propound a
supplemental interrogatory to elicit any later acquired information
bearing on all answers previously made by any party in response to
interrogatories.
(b) A party may propound a supplemental interrogatory twice before
the initial setting of a trial date, and, subject to the time limits
on discovery proceedings and motions provided in Chapter 8
(commencing with Section 2024.010), once after the initial setting of
a trial date.
(c) Notwithstanding subdivisions (a) and (b), on motion, for good
cause shown, the court may grant leave to a party to propound an
additional number of supplemental interrogatories.
2030.080. (a) The party propounding interrogatories shall serve a
copy of them on the party to whom the interrogatories are directed.
(b) The propounding party shall also serve a copy of the
interrogatories on all other parties who have appeared in the action.
On motion, with or without notice, the court may relieve the party
from this requirement on its determination that service on all other
parties would be unduly expensive or burdensome.
2030.090. (a) When interrogatories have been propounded, the
responding party, and any other party or affected natural person or
organization may promptly move for a protective order. This motion
shall be accompanied by a meet and confer declaration under Section
2016.040.
(b) The court, for good cause shown, may make any order that
justice requires to protect any party or other natural person or
organization from unwarranted annoyance, embarrassment, or
oppression, or undue burden and expense. This protective order may
include, but is not limited to, one or more of the following
directions:
(1) That the set of interrogatories, or particular interrogatories
in the set, need not be answered.
(2) That, contrary to the representations made in a declaration
submitted under Section 2030.050, the number of specially prepared
interrogatories is unwarranted.
(3) That the time specified in Section 2030.260 to respond to the
set of interrogatories, or to particular interrogatories in the set,
be extended.
(4) That the response be made only on specified terms and
conditions.
(5) That the method of discovery be an oral deposition instead of
interrogatories to a party.
(6) That a trade secret or other confidential research,
development, or commercial information not be disclosed or be
disclosed only in a certain way.
(7) That some or all of the answers to interrogatories be sealed
and thereafter opened only on order of the court.
(c) If the motion for a protective order is denied in whole or in
part, the court may order that the party provide or permit the
discovery against which protection was sought on terms and conditions
that are just.
(d) The court shall impose a monetary sanction under Chapter 7
(commencing with Section 2023.010) against any party, person, or
attorney who unsuccessfully makes or opposes a motion for a
protective order under this section, unless it finds that the one
subject to the sanction acted with substantial justification or that
other circumstances make the imposition of the sanction unjust.
2030.010. (a) Any party may obtain discovery within the scope
delimited by Chapters 2 (commencing with Section 2017.010) and 3
(commencing with Section 2017.710), and subject to the restrictions
set forth in Chapter 5 (commencing with Section 2019.010), by
propounding to any other party to the action written interrogatories
to be answered under oath.
(b) An interrogatory may relate to whether another party is making
a certain contention, or to the facts, witnesses, and writings on
which a contention is based. An interrogatory is not objectionable
because an answer to it involves an opinion or contention that
relates to fact or the application of law to fact, or would be based
on information obtained or legal theories developed in anticipation
of litigation or in preparation for trial.
2030.020. (a) A defendant may propound interrogatories to a party
to the action without leave of court at any time.
(b) A plaintiff may propound interrogatories to a party without
leave of court at any time that is 10 days after the service of the
summons on, or appearance by, that party, whichever occurs first.
(c) Notwithstanding subdivision (b), in an unlawful detainer
action or other proceeding under Chapter 4 (commencing with Section
1159) of Title 3 of Part 3, a plaintiff may propound interrogatories
to a party without leave of court at any time that is five days after
service of the summons on, or appearance by, that party, whichever
occurs first.
(d) Notwithstanding subdivisions (b) and (c), on motion with or
without notice, the court, for good cause shown, may grant leave to a
plaintiff to propound interrogatories at an earlier time.
2030.030. (a) A party may propound to another party either or both
of the following:
(1) Thirty-five specially prepared interrogatories that are
relevant to the subject matter of the pending action.
(2) Any additional number of official form interrogatories, as
described in Chapter 17 (commencing with Section 2033.710), that are
relevant to the subject matter of the pending action.
(b) Except as provided in Section 2030.070, no party shall, as a
matter of right, propound to any other party more than 35 specially
prepared interrogatories. If the initial set of interrogatories does
not exhaust this limit, the balance may be propounded in subsequent
sets.
(c) Unless a declaration as described in Section 2030.050 has been
made, a party need only respond to the first 35 specially prepared
interrogatories served, if that party states an objection to the
balance, under Section 2030.240, on the ground that the limit has
been exceeded.
2030.040. (a) Subject to the right of the responding party to seek
a protective order under Section 2030.090, any party who attaches a
supporting declaration as described in Section 2030.050 may propound
a greater number of specially prepared interrogatories to another
party if this greater number is warranted because of any of the
following:
(1) The complexity or the quantity of the existing and potential
issues in the particular case.
(2) The financial burden on a party entailed in conducting the
discovery by oral deposition.
(3) The expedience of using this method of discovery to provide to
the responding party the opportunity to conduct an inquiry,
investigation, or search of files or records to supply the
information sought.
(b) If the responding party seeks a protective order on the ground
that the number of specially prepared interrogatories is
unwarranted, the propounding party shall have the burden of
justifying the number of these interrogatories.
2030.050. Any party who is propounding or has propounded more than
35 specially prepared interrogatories to any other party shall attach
to each set of those interrogatories a declaration containing
substantially the following:
DECLARATION FOR ADDITIONAL DISCOVERY
I, __________, declare:
1. I am (a party to this action or proceeding appearing in propria
persona) (presently the attorney for __________, a party to this
action or proceeding).
2. I am propounding to __________ the attached set of
interrogatories.
3. This set of interrogatories will cause the total number of
specially prepared interrogatories propounded to the party to whom
they are directed to exceed the number of specially prepared
interrogatories permitted by Section 2030.030 of the Code of Civil
Procedure.
4. I have previously propounded a total of __________
interrogatories to this party, of which __________ interrogatories
were not official form interrogatories.
5. This set of interrogatories contains a total of __________
specially prepared interrogatories.
6. I am familiar with the issues and the previous discovery
conducted by all of the parties in the case.
7. I have personally examined each of the questions in this set of
interrogatories.
8. This number of questions is warranted under Section 2030.040 of
the Code of Civil Procedure because __________. (Here state each
factor described in Section 2030.040 that is relied on, as well as
the reasons why any factor relied on is applicable to the instant
lawsuit.)
9. None of the questions in this set of interrogatories is being
propounded for any improper purpose, such as to harass the party, or
the attorney for the party, to whom it is directed, or to cause
unnecessary delay or needless increase in the cost of litigation.
I declare under penalty of perjury under the laws of California
that the foregoing is true and correct, and that this declaration was
executed on __________.
__________________________________________________
(Signature)
Attorney for______________________________________
2030.060. (a) A party propounding interrogatories shall number each
set of interrogatories consecutively.
(b) In the first paragraph immediately below the title of the
case, there shall appear the identity of the propounding party, the
set number, and the identity of the responding party.
(c) Each interrogatory in a set shall be separately set forth and
identified by number or letter.
(d) Each interrogatory shall be full and complete in and of
itself. No preface or instruction shall be included with a set of
interrogatories unless it has been approved under Chapter 17
(commencing with Section 2033.710).
(e) Any term specially defined in a set of interrogatories shall
be typed with all letters capitalized wherever that term appears.
(f) No specially prepared interrogatory shall contain subparts, or
a compound, conjunctive, or disjunctive question.
(g) An interrogatory may not be made a continuing one so as to
impose on the party responding to it a duty to supplement an answer
to it that was initially correct and complete with later acquired
information.
2030.070. (a) In addition to the number of interrogatories
permitted by Sections 2030.030 and 2030.040, a party may propound a
supplemental interrogatory to elicit any later acquired information
bearing on all answers previously made by any party in response to
interrogatories.
(b) A party may propound a supplemental interrogatory twice before
the initial setting of a trial date, and, subject to the time limits
on discovery proceedings and motions provided in Chapter 8
(commencing with Section 2024.010), once after the initial setting of
a trial date.
(c) Notwithstanding subdivisions (a) and (b), on motion, for good
cause shown, the court may grant leave to a party to propound an
additional number of supplemental interrogatories.
2030.080. (a) The party propounding interrogatories shall serve a
copy of them on the party to whom the interrogatories are directed.
(b) The propounding party shall also serve a copy of the
interrogatories on all other parties who have appeared in the action.
On motion, with or without notice, the court may relieve the party
from this requirement on its determination that service on all other
parties would be unduly expensive or burdensome.
2030.090. (a) When interrogatories have been propounded, the
responding party, and any other party or affected natural person or
organization may promptly move for a protective order. This motion
shall be accompanied by a meet and confer declaration under Section
2016.040.
(b) The court, for good cause shown, may make any order that
justice requires to protect any party or other natural person or
organization from unwarranted annoyance, embarrassment, or
oppression, or undue burden and expense. This protective order may
include, but is not limited to, one or more of the following
directions:
(1) That the set of interrogatories, or particular interrogatories
in the set, need not be answered.
(2) That, contrary to the representations made in a declaration
submitted under Section 2030.050, the number of specially prepared
interrogatories is unwarranted.
(3) That the time specified in Section 2030.260 to respond to the
set of interrogatories, or to particular interrogatories in the set,
be extended.
(4) That the response be made only on specified terms and
conditions.
(5) That the method of discovery be an oral deposition instead of
interrogatories to a party.
(6) That a trade secret or other confidential research,
development, or commercial information not be disclosed or be
disclosed only in a certain way.
(7) That some or all of the answers to interrogatories be sealed
and thereafter opened only on order of the court.
(c) If the motion for a protective order is denied in whole or in
part, the court may order that the party provide or permit the
discovery against which protection was sought on terms and conditions
that are just.
(d) The court shall impose a monetary sanction under Chapter 7
(commencing with Section 2023.010) against any party, person, or
attorney who unsuccessfully makes or opposes a motion for a
protective order under this section, unless it finds that the one
subject to the sanction acted with substantial justification or that
other circumstances make the imposition of the sanction unjust.
2030.010. (a) Any party may obtain discovery within the scope
delimited by Chapters 2 (commencing with Section 2017.010) and 3
(commencing with Section 2017.710), and subject to the restrictions
set forth in Chapter 5 (commencing with Section 2019.010), by
propounding to any other party to the action written interrogatories
to be answered under oath.
(b) An interrogatory may relate to whether another party is making
a certain contention, or to the facts, witnesses, and writings on
which a contention is based. An interrogatory is not objectionable
because an answer to it involves an opinion or contention that
relates to fact or the application of law to fact, or would be based
on information obtained or legal theories developed in anticipation
of litigation or in preparation for trial.
2030.020. (a) A defendant may propound interrogatories to a party
to the action without leave of court at any time.
(b) A plaintiff may propound interrogatories to a party without
leave of court at any time that is 10 days after the service of the
summons on, or appearance by, that party, whichever occurs first.
(c) Notwithstanding subdivision (b), in an unlawful detainer
action or other proceeding under Chapter 4 (commencing with Section
1159) of Title 3 of Part 3, a plaintiff may propound interrogatories
to a party without leave of court at any time that is five days after
service of the summons on, or appearance by, that party, whichever
occurs first.
(d) Notwithstanding subdivisions (b) and (c), on motion with or
without notice, the court, for good cause shown, may grant leave to a
plaintiff to propound interrogatories at an earlier time.
2030.030. (a) A party may propound to another party either or both
of the following:
(1) Thirty-five specially prepared interrogatories that are
relevant to the subject matter of the pending action.
(2) Any additional number of official form interrogatories, as
described in Chapter 17 (commencing with Section 2033.710), that are
relevant to the subject matter of the pending action.
(b) Except as provided in Section 2030.070, no party shall, as a
matter of right, propound to any other party more than 35 specially
prepared interrogatories. If the initial set of interrogatories does
not exhaust this limit, the balance may be propounded in subsequent
sets.
(c) Unless a declaration as described in Section 2030.050 has been
made, a party need only respond to the first 35 specially prepared
interrogatories served, if that party states an objection to the
balance, under Section 2030.240, on the ground that the limit has
been exceeded.
2030.040. (a) Subject to the right of the responding party to seek
a protective order under Section 2030.090, any party who attaches a
supporting declaration as described in Section 2030.050 may propound
a greater number of specially prepared interrogatories to another
party if this greater number is warranted because of any of the
following:
(1) The complexity or the quantity of the existing and potential
issues in the particular case.
(2) The financial burden on a party entailed in conducting the
discovery by oral deposition.
(3) The expedience of using this method of discovery to provide to
the responding party the opportunity to conduct an inquiry,
investigation, or search of files or records to supply the
information sought.
(b) If the responding party seeks a protective order on the ground
that the number of specially prepared interrogatories is
unwarranted, the propounding party shall have the burden of
justifying the number of these interrogatories.
2030.050. Any party who is propounding or has propounded more than
35 specially prepared interrogatories to any other party shall attach
to each set of those interrogatories a declaration containing
substantially the following:
DECLARATION FOR ADDITIONAL DISCOVERY
I, __________, declare:
1. I am (a party to this action or proceeding appearing in propria
persona) (presently the attorney for __________, a party to this
action or proceeding).
2. I am propounding to __________ the attached set of
interrogatories.
3. This set of interrogatories will cause the total number of
specially prepared interrogatories propounded to the party to whom
they are directed to exceed the number of specially prepared
interrogatories permitted by Section 2030.030 of the Code of Civil
Procedure.
4. I have previously propounded a total of __________
interrogatories to this party, of which __________ interrogatories
were not official form interrogatories.
5. This set of interrogatories contains a total of __________
specially prepared interrogatories.
6. I am familiar with the issues and the previous discovery
conducted by all of the parties in the case.
7. I have personally examined each of the questions in this set of
interrogatories.
8. This number of questions is warranted under Section 2030.040 of
the Code of Civil Procedure because __________. (Here state each
factor described in Section 2030.040 that is relied on, as well as
the reasons why any factor relied on is applicable to the instant
lawsuit.)
9. None of the questions in this set of interrogatories is being
propounded for any improper purpose, such as to harass the party, or
the attorney for the party, to whom it is directed, or to cause
unnecessary delay or needless increase in the cost of litigation.
I declare under penalty of perjury under the laws of California
that the foregoing is true and correct, and that this declaration was
executed on __________.
__________________________________________________
(Signature)
Attorney for______________________________________
2030.060. (a) A party propounding interrogatories shall number each
set of interrogatories consecutively.
(b) In the first paragraph immediately below the title of the
case, there shall appear the identity of the propounding party, the
set number, and the identity of the responding party.
(c) Each interrogatory in a set shall be separately set forth and
identified by number or letter.
(d) Each interrogatory shall be full and complete in and of
itself. No preface or instruction shall be included with a set of
interrogatories unless it has been approved under Chapter 17
(commencing with Section 2033.710).
(e) Any term specially defined in a set of interrogatories shall
be typed with all letters capitalized wherever that term appears.
(f) No specially prepared interrogatory shall contain subparts, or
a compound, conjunctive, or disjunctive question.
(g) An interrogatory may not be made a continuing one so as to
impose on the party responding to it a duty to supplement an answer
to it that was initially correct and complete with later acquired
information.
2030.070. (a) In addition to the number of interrogatories
permitted by Sections 2030.030 and 2030.040, a party may propound a
supplemental interrogatory to elicit any later acquired information
bearing on all answers previously made by any party in response to
interrogatories.
(b) A party may propound a supplemental interrogatory twice before
the initial setting of a trial date, and, subject to the time limits
on discovery proceedings and motions provided in Chapter 8
(commencing with Section 2024.010), once after the initial setting of
a trial date.
(c) Notwithstanding subdivisions (a) and (b), on motion, for good
cause shown, the court may grant leave to a party to propound an
additional number of supplemental interrogatories.
2030.080. (a) The party propounding interrogatories shall serve a
copy of them on the party to whom the interrogatories are directed.
(b) The propounding party shall also serve a copy of the
interrogatories on all other parties who have appeared in the action.
On motion, with or without notice, the court may relieve the party
from this requirement on its determination that service on all other
parties would be unduly expensive or burdensome.
2030.090. (a) When interrogatories have been propounded, the
responding party, and any other party or affected natural person or
organization may promptly move for a protective order. This motion
shall be accompanied by a meet and confer declaration under Section
2016.040.
(b) The court, for good cause shown, may make any order that
justice requires to protect any party or other natural person or
organization from unwarranted annoyance, embarrassment, or
oppression, or undue burden and expense. This protective order may
include, but is not limited to, one or more of the following
directions:
(1) That the set of interrogatories, or particular interrogatories
in the set, need not be answered.
(2) That, contrary to the representations made in a declaration
submitted under Section 2030.050, the number of specially prepared
interrogatories is unwarranted.
(3) That the time specified in Section 2030.260 to respond to the
set of interrogatories, or to particular interrogatories in the set,
be extended.
(4) That the response be made only on specified terms and
conditions.
(5) That the method of discovery be an oral deposition instead of
interrogatories to a party.
(6) That a trade secret or other confidential research,
development, or commercial information not be disclosed or be
disclosed only in a certain way.
(7) That some or all of the answers to interrogatories be sealed
and thereafter opened only on order of the court.
(c) If the motion for a protective order is denied in whole or in
part, the court may order that the party provide or permit the
discovery against which protection was sought on terms and conditions
that are just.
(d) The court shall impose a monetary sanction under Chapter 7
(commencing with Section 2023.010) against any party, person, or
attorney who unsuccessfully makes or opposes a motion for a
protective order under this section, unless it finds that the one
subject to the sanction acted with substantial justification or that
other circumstances make the imposition of the sanction unjust.
