How to Answer Form Interrogatory Number 17.1 from the California Form Interrogatories
California Form Interrogatories are important tools in litigation. This interrogatory is served with a request for admissions. This interrogatory is important because it explains why a party has denied a Request for Admissions, and allows the asking party to detail why the party is not admitting to certain facts.
The text of Form Interrogatory Number 17.1 is:
Is your response to each request for admission served with these interrogatories an unqualified admission? If not, for each response that is not an unqualified admission:
(a) state the number of the request;
(b) state all facts upon which you base your response;
(c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of those facts; and
(d) identify all DOCUMENTS and other tangible things that support your response and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. Form Interrogatory 17.1 California Judicial Council Form DISC-001 (Revised January 1, 2008),
If the Request for Admission, Number 9 is “Please admit that YOU own the property where the PLAINTIFF was injured on the date of the INCIDENT," and you did not admit the Request for Admission, the response would be
Response to Form Interrogatory Number 17.1:
(a) Request for Admissions, Set One, Request 9;
(b) Defendant did not own the property where the Plaintiff was injured on the date of the incident because Defendant had sold the property to Cross-Defendant City of Rancho Muscupiabe, on August 21, 2009;
(c) Defendant, 1255 W. Colton Avenue #104, Redlands, California, (909) 708-6055; Cr0ss-Defendant City of Rancho Muscupiabe, 1200 Hill Drive, Rancho Muscupiabe, CA 92407, (909) 708-6055.
(d) Quitclaim deed, a recorded copy which is in possession of Cross-Defendant City of Rancho Muscupiabe, 1200 Hill Drive, Rancho Muscupiabe, CA 92407, (909) 708-6055.
If each response to the Request for Admission is an unqualified admission, then the answering party must simply respond to Form Interrogatory 17.1 in this way. Response to Form Interrogatory Number 17.1: