Actually you cannot include instructions with special interrogatories. Special interrogatories are those you write yourself, while form interrogatories (which have instructions) are written by the judicial council.
The definitions you use in interrogatories are also specially drafted, that is, you create your own definitions for things that must be defined. You can use the definitions on the form interrogatories with your special interrogatories, if they apply.
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I agree with Attorney Bennett. You don't need instructions because they are prohibited under the Code of Civil Procedure.
If you wish to have definitions within your interrogatories, you need to define them the first time you use the term (and make sure you always CAPITALIZE the defined word throughout the entire set of interrogatories.
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In addition to the fine previous answers, I would only remind you that in a limited civil case you are limited to a 'grab bag' of 35 requests per opposing party. The 35 limit is in total of all things - form rogs, specials, requests for admission, and production of documents.
Richard A. Rodgers, Esq.
200 N. Westlake Blvd. Ste 201
Westlake Village, CA 91362
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