State Court Discovery - Interrogatories - California

California Litigation & Court Documents Updated October 5, 2026 Free Word and PDF

SUPERIOR COURT OF CALIFORNIA, COUNTY OF [COUNTY]

Party Role
[PLAINTIFF NAME] Plaintiff
v.
[DEFENDANT NAME] Defendant
Case detail Entry
Case number [CASE NUMBER]
Department / judge [DEPARTMENT / JUDGE]

SPECIAL INTERROGATORIES (SET [SET NUMBER]) TO [RESPONDING PARTY]

[PROPONDING PARTY] propounds this Set [SET NUMBER] of specially prepared interrogatories to [RESPONDING PARTY].

  1. Identify each person who witnessed the event alleged in paragraph [NUMBER] of the [PLEADING].
  2. State all facts supporting your contention that [IDENTIFIED PARTY] was comparatively negligent in the event alleged in paragraph [NUMBER] of the [PLEADING].
  3. Identify each written policy in effect on [DATE] concerning [SPECIFIC SUBJECT].
  4. State the total amount of medical expenses you contend resulted from the event alleged in paragraph [NUMBER] of the [PLEADING].
  5. State the total amount of lost earnings you contend resulted from the event alleged in paragraph [NUMBER] of the [PLEADING].
  6. Identify each liability insurance policy you contend may cover a judgment on [IDENTIFIED CLAIM] in this action.
  7. Identify each expert witness you presently intend to call at trial on [IDENTIFIED ISSUE].
  8. State all facts supporting your affirmative defense of [SPECIFIC DEFENSE] pleaded in paragraph [NUMBER] of the [ANSWER].

Dated: [__/__/____]

[PROPONDING PARTY OR COUNSEL]

By: ______________________________

[NAME / CALIFORNIA BAR NUMBER, IF COUNSEL]

[ADDRESS, TELEPHONE, EMAIL]

PROOF OF SERVICE

I am at least 18 years old, am not a party to this action, and am a resident of or employed in [COUNTY] County, California. My residence or business address is [ADDRESS]. On [__/__/____], I served Special Interrogatories (Set [SET NUMBER]) to [RESPONDING PARTY] and [DECLARATION FOR ADDITIONAL DISCOVERY / NO DECLARATION] on [RECIPIENT NAME AND MAILING ADDRESS] as follows:

I placed true copies in a sealed, postage-paid envelope addressed as stated above and deposited it with the United States Postal Service at [CITY], [COUNTY] County, California.

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.

Executed on [__/__/____] at [CITY], California.

Signature: ______________________________ Printed name: [____________________]

DECLARATION FOR ADDITIONAL DISCOVERY (IF APPLICABLE)

I, [DECLARANT NAME], declare:

  1. I am ☐ a party appearing without counsel ☐ presently the attorney for [PARTY], a party to this action.
  2. I am propounding to [RESPONDING PARTY] the attached set of interrogatories.
  3. This set will cause the total number of specially prepared interrogatories propounded to this responding party to exceed the number permitted by Cal. Code Civ. Proc. § 2030.030.
  4. I previously propounded [TOTAL] interrogatories to this party, of which [NUMBER] were not official form interrogatories.
  5. This set contains [NUMBER] specially prepared interrogatories.
  6. I am familiar with the issues and the previous discovery conducted by all parties in this case.
  7. I have personally examined each question in this set.
  8. This number of questions is warranted under Cal. Code Civ. Proc. § 2030.040 because [STATE EACH APPLICABLE STATUTORY FACTOR AND CASE-SPECIFIC REASONS].
  9. No question in this set is propounded for an improper purpose, including harassment, unnecessary delay, or needless increase in litigation cost.

I declare under penalty of perjury under the laws of California that the foregoing is true and correct.

Executed on [__/__/____] at [CITY], California.

Signature: ______________________________ Printed name / title: [____________________]

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About this template

Last updated
October 5, 2026
Citations checked
October 5, 2026
Jurisdiction
California
Category
Litigation & Court Documents

Legal authority

  • Cal. Code Civ. Proc. § 2030.030 (35 special interrogatories per responding party, subject to exceptions)
  • Cal. Code Civ. Proc. § 2030.040 (grounds for additional interrogatories)
  • Cal. Code Civ. Proc. § 2030.050 (declaration for additional interrogatories)
  • Cal. Code Civ. Proc. § 2030.060 (form and content of special interrogatories)
  • Cal. Code Civ. Proc. § 2030.260 (response time and exceptions)
  • Cal. Code Civ. Proc. § 1013 (mail service)
  • Cal. Code Civ. Proc. § 1013a (mail service proof)
  • Cal. Code Civ. Proc. § 2015.5 (declaration under penalty of perjury)

These are the filings that drive a lawsuit through the system: complaints, answers, motions, briefs, discovery requests and responses, and post-judgment papers. Each has its own format requirements under federal and state procedural rules, and each has a deadline that cannot be missed without consequences. Clean, procedurally correct filings move a case forward; sloppy ones invite motions to strike, amended responses, and avoidable delays.

Not legal advice

This template is provided for informational purposes. We recommend having an attorney review any legal document before signing, especially for high-value or complex matters.

Checked against the law it cites

A reviewer verified this template's legal citations against the official source on October 5, 2026.

Cal. Code Civ. Proc. § 2030.030(a) (checked October 5, 2026): "Thirty-five specially prepared interrogatories that are relevant to the subject matter of the pending action."

Cal. Code Civ. Proc. § 2030.050 (checked October 5, 2026): "Any party who is propounding or has propounded more than 35 specially prepared interrogatories to any other party shall attach to each set of those interrogatories a declaration containing substantially the following:"

Cal. Code Civ. Proc. § 2030.060(d) (checked October 5, 2026): "Each interrogatory shall be full and complete in and of itself. No preface or instruction shall be included with a set of interrogatories unless it has been approved under Chapter 17"

Cal. Code Civ. Proc. § 2030.060(f) (checked October 5, 2026): "No specially prepared interrogatory shall contain subparts, or a compound, conjunctive, or disjunctive question."

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