State Court Discovery - Interrogatories

CALIFORNIA INTERROGATORY PREPARATION WORKSHEET

NOT FOR FILING OR SERVICE

Use this worksheet to organize a case-specific drafting plan. It is not a set of interrogatories. Do not serve its question bank or copy its instructions without checking the current law, orders, and facts of the pending case.

I. CASE CONTROL

II. CURRENT-LAW AND CASE-ORDER CONTROL

Complete before drafting or service:

Counsel or reviewer: [________________________________________]

Review date: [__/__/____]

III. PLEADING-TO-QUESTION MAP

Use one row for each proposed subject. Delete subjects that are not tied to an authorized purpose in the pending case.

IV. DRAFT DEFINITIONS

Tailor each definition to the pleadings, relevant period, and current discovery scope. Delete any definition that broadens the requests beyond what counsel has approved.

1. “Action” means [CASE-SPECIFIC DESCRIPTION].

2. “Communication” means [CASE-SPECIFIC DEFINITION].

3. “Document” means [CASE-SPECIFIC DEFINITION CONSISTENT WITH CURRENT LAW AND ANY ORDER].

4. “Identify” means [INFORMATION AUTHORIZED FOR THE PARTICULAR PERSON, ENTITY, EVENT, OR MATERIAL].

5. “Person” means [CASE-SPECIFIC DEFINITION].

6. “You” and “Your” mean [RESPONDING PARTY]. Any proposed extension to personnel, agents, affiliates, or other persons must be separately reviewed and justified.

7. Relevant time period: [________________________________________].

V. DRAFT INSTRUCTIONS

Do not use boilerplate instructions without current review. Prepare case-ready instructions addressing only the topics that apply, including:

• how each interrogatory is to be answered or objected to;
• treatment of any unobjectionable portion;
• the selected response deadline;
• the selected privilege or protection procedure;
• any supplementation or correction obligation;
• the relevant time period and geographic scope;
• terminology that matches the responding party's information systems;
• confidentiality, personal-information, and protective-order restrictions; and
• the current signature, execution, filing, and service procedure.

Avoid automatic constructions that broaden “and,” “or,” “all,” “each,” “concerning,” or a party definition beyond the reviewed scope.

VI. CANDIDATE QUESTION BANK

These are drafting prompts only. Select, narrow, separate, renumber, and link each candidate to the control tables. Delete every unused question and check any applicable form or special-interrogatory distinction.

Persons and events

1. Identify each person with knowledge of [SPECIFIC EVENT OR ALLEGATION] and describe the subject of that knowledge.

2. State the facts supporting [SPECIFIC ALLEGATION, DENIAL, OR DEFENSE].

3. Describe the role of each person who participated in [SPECIFIC EVENT].

4. Identify each communication concerning [NARROW SUBJECT] during [RELEVANT PERIOD].

Documents and information systems

5. Identify the documents supporting [SPECIFIC CONTENTION].

6. Identify the custodian and location of [SPECIFIC CATEGORY OF INFORMATION].

7. Describe the information systems reasonably likely to contain [SPECIFIC INFORMATION], including the relevant custodians and period.

8. Describe the retention practice applicable to [SPECIFIC CATEGORY] during [RELEVANT PERIOD].

Claims, defenses, and damages

9. State the factual basis for [IDENTIFIED CLAIM OR DEFENSE].

10. Identify the documents and persons supporting [IDENTIFIED CLAIM OR DEFENSE].

11. Identify each category of damages or other relief attributed to [SPECIFIC CONDUCT].

12. State the method used to calculate [SPECIFIC DAMAGES CATEGORY].

13. State the facts supporting any contention concerning mitigation of [SPECIFIC LOSS].

14. State the facts supporting any contention that another identified person caused or contributed to [SPECIFIC HARM].

Policies and practices

15. Identify the policy, procedure, or training material in effect during [RELEVANT PERIOD] concerning [SPECIFIC SUBJECT].

16. Describe how [IDENTIFIED POLICY OR PROCEDURE] applied to [SPECIFIC EVENT].

17. Identify each person responsible for implementing or supervising [IDENTIFIED POLICY OR PROCEDURE].

VII. QUESTION-BY-QUESTION REVIEW

VIII. DRAFTING AND EXECUTION PLAN

If preparing responses in a separate workflow, determine the current signer, representative capacity, oath or verification, signature, and execution requirements from the control table. Do not assume a sample response block belongs in the propounding document.

IX. SERVICE AND DEADLINE RECORD

Complete from the current service rule, case docket, agreements, and orders:

X. FINAL REVIEW

☐ Court, county, case classification, department, parties, and case number confirmed

☐ Current rules, orders, and local procedures entered in the control table

☐ Count and subpart treatment checked after final numbering

☐ Every question linked to a pleaded claim, defense, or authorized issue

☐ Definitions and instructions narrowed to the case

☐ Privilege, privacy, confidentiality, and protective-order issues reviewed

☐ Duplicative, compound, ambiguous, argumentative, and overbroad questions removed or revised

☐ Deadline calculation independently reviewed

☐ Signature, execution, filing, service, and proof requirements confirmed

☐ Final served paper matches the reviewed draft

Retain this worksheet with the current authorities, orders, final discovery, service record, and deadline calculation.