Thanks in advance.
Real Estate Attorney
Yes. Thirty five separate requests, total.
Yes. See California Code of Civil Procedure section 94, subdivision (a)(1) - (3).
You're also only allowed one deposition. See Cal. Code Civ. Proc. section 94, subdivision (b).
A good idea, though, is to serve a case questionnaire with the complaint as authorized by section 93. That way you can get basic information like names, addresses, witnesses, etc. without having to waste any of your 35 questions.
This response does not create an attorney-client relationship between you and I. I am not your lawyer and I am not representing you in the underlying issue stated in your question. The response I have offered is not intended to be relied upon, you should seek out an attorney to assist in this matter.