Q: How many RFAs' and Rogs' questions can I ask in unlimited Civil lawsuits in California?

A: In California, the limits for written discovery in unlimited civil cases are as follows:

1. Form Interrogatories (FI): No limit on the number of Form Interrogatories you can ask.

2. Special Interrogatories (SI): You are limited to 35 specially prepared interrogatories per party, unless the court grants permission for additional interrogatories.

3. Requests for Admission (RFA): There is no specific limit on the number of RFAs you can ask. However, the requests must be relevant to the case and not be unduly burdensome.

The 35-question limit applies only to Special Interrogatories and does not include Form Interrogatories or Requests for Admission.

To make efficient use of your Special Interrogatories without exceeding the 35-question limit:

1. Carefully plan your questions to cover the most important information you need.

2. Use Form Interrogatories whenever possible, as they don't count toward the 35-question limit.

3. If you need to ask more than 35 Special Interrogatories, consider requesting the court's permission to do so by demonstrating good cause.

4. Utilize Requests for Admission to establish facts that you believe are not in dispute, as this can save you from using interrogatories to gather the same information.

Remember that while there is no specific limit on RFAs, they should still be relevant and not unduly burdensome. If the opposing party finds them excessive, they may object or seek a protective order from the court.