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California Points & Authorities
Copyright 2017, Matthew Bender & Company, Inc., a member of the LexisNexis Group.

8-84 California Points & Authorities 84.syn


Discovery: Interrogatories


The Matthew Bender Editorial Staff

Chapter Summary


Civil discovery in California is governed primarily by the California Civil Discovery Act. Interrogatories are one commonly used form of civil discovery. They consist of a set or series of written questions about the case submitted by one party to the other party or a witness to be answered and generally signed with a sworn statement as to their truth.

This chapter of California Points and Authorities contains memoranda relating to civil discovery by written interrogatories. It includes memoranda supporting and opposing a motion to compel matters relating to discovery by interrogatories, memoranda supporting a motion for a protective order in the context of written interrogatories, and memoranda relating to miscellaneous motions in matters pertaining to interrogatories, including a motion for relief from a waiver of the right to produce writings or make objections and a motion to deem partial answers to interrogatories as binding.

California Points and Authorities is the only California publication to provide forms that combine concise arguments of the law with accurate summaries of supporting statutes, cases, and rules. Easily adaptable for use in trial and appellate briefs and researching jury instructions, the forms are designed to assist the attorney in arguing points of law at all stages of litigation.


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For memoranda supporting or opposing a motion to compel discovery based on general limiting or regulatory provisions of the Discovery Act, see Ch. 80, Discovery: Scope, Regulation, and Timing.

For memoranda supporting or opposing a motion to compel discovery on the ground that the matter sought to be discovered is privileged or is otherwise protected from disclosure, see Ch. 81, Discovery: Privileges and Other Discovery Limitations.

For memoranda supporting or opposing a motion to compel discovery, or supporting or opposing a motion for protective order, in the context of another discovery method, see Ch. 83, Discovery: Depositions, and Ch. 85, Discovery: Production or Inspection of Tangible Evidence, through Ch. 88, Discovery: Exchange of Expert Witness Information.

For memoranda for use in seeking or opposing writs to review discovery orders, see Ch. 89A, Discovery: Review of Discovery Orders.

For memoranda of points and authorities regarding relief under Cal. Code Civ. Proc. § 473, see Ch. 70, Defaults, Default Judgments, and Relief from Judgments and Orders.


See Matthew Bender(R) Practice Guide: California Civil Discovery (Matthew Bender) for all the information you need to handle discovery requests and responses including interrogatories, requests for admissions and depositions, plus detailed information regarding topics such as electronic discovery and sanctions.

See Matthew Bender(R) Practice Guide: California Pretrial Civil Procedure (Matthew Bender) for precise guidance on finding pertinent online information, cross-references to relevant content, icons classified by type, and an abundance of checklists and forms that you can't find elsewhere.

For background discussion of forms of moving papers relating to civil discovery by written interrogatories, see California Forms of Pleading and Practice, Ch. 194, Discovery: Interrogatories (Matthew Bender).

For discussion and forms regarding sanctions for discovery generally, see California Forms of Pleading and Practice, Ch. 192, Discovery: Sanctions for Discovery Misuse (Matthew Bender).
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