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I've been trying to find the form for a specific objection to an interrogatory.

Los Angeles, CA |

The defense asks a question based on facts never alleged in any of the pleadings. There has to be an objection for this, but I cannot seem to find it. Can someone point me in the right direction as to where to look?

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Attorney answers 3


An interrogatory must request information that is likely to lead to the discovery of admissible evidence. That is a very broad standard, but if you in good faith do not believe that the interrogatory seeks such information, it is your right to assert an objection. You need to serve your responses in a timely fashion. Otherwise, the objection could be waived.

THIS RESPONSE IS NOT LEGAL ADVICE. IT HAS BEEN PROVIDED FOR EDUCATION AND INFORMATION ONLY. Mr. Mann is licensed to practice in the State of California. There is no implied or actual attorney-client relationship arising from this educational exchange. Moreover, the facts provided by you were not sufficient to allow Mr. Mann to advise you specifically regarding what you should or should not do. You should speak with an attorney licensed in your state, to whom you have provided all the facts before you take steps that may impact your legal rights. Mr. Mann is under no obligation to answer subsequent emails or phone calls related to this matter, or to take any action whatsoever.


You should object on the basis that the Interrogatory is not reasonably calculated to lead to the discovery of admissible evidence. The scope of discovery is broad, and you should probably provide an answer subject to your objection, unless you are trying to assert a privilege, which doesn't seem likely because you appear to be representing yourself. Check the local rules of the court that your case is filed and consider consulting with a local attorney.


The questions and information sought in discovery do not have to be strictly limited to facts plead in any of the pleadings. Parties in discovery are entitled to information, documents and other tangible evidence that may have a tendency to lead to the discovery of admissible evidence.

The information and documents exchanged in discovery may nonetheless be excluded from evidence at the trial on the matter, but that does not mean the party are not entitled to such documents and information during discovery.

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.

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