Q: Interrogatory/demand correlation is mandatory, or optional upon situation

A: In California, interrogatories and requests for production of documents are two separate discovery tools, and they are not necessarily required to match or correlate with each other.

1. Interrogatories: These are written questions that one party sends to another, requiring the responding party to answer under oath. Interrogatories are used to obtain information and facts related to the case.

2. Requests for Production of Documents: These are demands for the opposing party to provide specific documents or tangible evidence relevant to the case.

While it is common for interrogatories and requests for production to cover related topics, they are not required to have a one-to-one correlation. In your example, a request for production of a specific contractual or employment agreement does not necessarily require a corresponding interrogatory to identify the agreement, as the request itself is clear and specific.

However, in some situations, it may be beneficial to have a corresponding interrogatory to provide additional context or clarification. This can help avoid potential objections or disputes over the scope or relevance of the requested documents.

Ultimately, the decision to include a matching interrogatory for a specific document request depends on the specific circumstances of the case and the legal strategy employed by the attorney. It is not mandatory but can be helpful in certain situations to ensure clarity and compliance with the discovery request.