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If I included definitions with my special interrogatories does that make them invalid not requiring an answer from the defendant

Oakland, CA |

I am the moving party. The case is is an unlimited jurisdiction matter in northern California. I sent over special interrogatories which included definitions and other information I copied over from form rogs from the ca judicial council site. Are my special rogs defective not requiring an answer? How can I cure this defect?

Attorney Answers 1


You cannot copy the definitions from the Judicial Council form interrogatories for use in specially prepared interrogatories.

If your special interrogatories contained impermissible definitions, these interrogatories are objectionable based upon Code of Civil Procedure section 2030.060, subdivisions (d), (e) and/or (f).

Therefore, if the responding party objected on the grounds that the interrogatories contained definitions, the defendant does not have to substantively answer the interrogatories. You won't be able to cure this defect. However, you should meet and confer with the opposing side to see if you can resolve the objections BEFORE you attempt to file a motion to compel further responses.

The information presented here is general in nature and is not intended, nor should be construed, as legal advice. This posting does not create any attorney-client relationship with the author (who is only admitted to practice law in the State of California). For specific advice about your particular situation, consult your own attorney.

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The responding party never objected within the 30 days allowed to respond. Have they therefore waived their right to object and I can now move forward with my MTC?

Frank Wei-Hong Chen

Frank Wei-Hong Chen


They may have waived their right to object if the 30 days have already passed. However, whether you can proceed with a motion to compel depends upon how good the interrogatories are phrased, because if the interrogatories are wholly lacking, you might not only lose the MTC but also be sanctioned and end up having to pay the other side's attorney's fees and costs for opposing your MTC.



I'll take a look but I doubt seriously I would have drafted anything I couldnt win a MTC in open court based on my written pleading and my oral arguements. Its been my experience that most of the folks I'll face lack the ability to stand and deliver, Not everyone is as cool or as competent as you Mr. Frank. If they were I wouldnt be on this site I'd be paying someone else to do this stuff for me. As long as I run into folks not like you I'll be just fine. I'm also mature enough to know when to write you a check. I came close about a month ago with my little walk thru federal court.

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