In a postjudgment family law matter my ex-husband’s attorney served me with some special interrogatories. CCP 2030.060 (d) states that “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).” However, his special interrogatories include special definitions of some terms and, most importantly appear not to be full and complete in themselves. Many interrogatories refer to other interrogatories, for example, “relating to your response to the previous interrogatory, identify all documents which support your response.” Is this form correct?
This case might help:
(Clement v. Alegre (2009) 177 Cal.App.4th 1277, 1287.)
There is an article here:http://thecomplexlitigator.com/post-data/2009/9/24/its-about-time-for-a-reminder-about-the-purpose-of-discovery.html
Not surpisingly, Clement kills this objection and hit the lawyer with $6,000 in sanctions. I just can't believe Clement spent almost four pages talking about this throw-away objection (guess the court was pissed). Basically, Clement makes clear that the rule is simply meant to prevent parties from circumventing the "rule of 35" -- parties may only propound 35 specially prepared interrogatories. So, the rule is now that references to previous rogs, and outside materials/documents, is only prohibited where the effect is to undermine the rule of 35 (i.e., by asking a single rog about the "truthfulness" of a party's 10,000 deposition answers). (Id. at p. 1290.)
Objecting to discovery that you are going to be required to give anyway defeats the entire purpose of discovery. Answer the parts of the queries that you understand. Object to the parts that you do not. Read the article proposed by my colleague. Good luck.
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