Q: Amount of special interrogatories thoughout discovery.
How many interrogatories overall during discovery a party is allowed to propound?
A: In California there is no limit as long as a declaration is added of more than 35. If the amount is unreasonable on can object and or bring a motion.
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A:
Under California law, per the Code of Civil Procedure Section 2030.030, a party may propound a maximum of 35 specially prepared interrogatories to any other party. This limit applies throughout the entire discovery process, not per set of interrogatories.
However, there are a few exceptions to this limit:
1. If a party declares under penalty of perjury that more than 35 interrogatories are necessary, they may propound additional interrogatories.
2. The court may grant permission to a party to propound a greater number of interrogatories upon a showing of good cause.
3. The 35 interrogatory limit does not apply to official Judicial Council form interrogatories, which are pre-approved sets of interrogatories for specific case types, such as employment law or unlawful detainer cases.
It's important to note that each subsection of an interrogatory is counted as a separate interrogatory for the purpose of this limit. Parties should carefully draft their interrogatories to ensure they gather the necessary information within the prescribed limit.
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