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Sample Supplemental Responses to Interrogatories

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Yuke

Member
What is the name of your state? CA

Does anyone have a sample demand for supplemental response to interrogatories, particularly for form interrogatories?

Can I append a form FI-120 to the document?

Where do I indicate which interrogatories I want further response from? In the brief? a separate declaration?




Thanks! I'm not a litigator, just a patent attorney helping out.
 
Last edited:


I AM ALWAYS LIABLE

Senior Member
Yuke said:
What is the name of your state? CA

Does anyone have a sample demand for supplemental response to interrogatories, particularly for form interrogatories?

Can I append a form FI-120 to the document?

Where do I indicate which interrogatories I want further response from? In the brief? a separate declaration?

Thanks! I'm not a litigator, just a patent attorney helping out.

=====================================

My response:

Counselor, I would strongly suggest - - in fact, I'd advise you - - that you thoroughly read CCP 2030, and follow each and every applicable word very closely - - especially for your pleading format. One misstep, and your supplemental interrogatory would be objectionable.

Secondly, as a litigator myself, NEVER discriminate between those interrogatories that you do, and you don't, want supplemented. If you do, you're laying out a "roadmap" to your strategy, giving the other side valuable information as to which information is more important to you and your case. So, you write a generic supplemental interrogatory, as follows:

Following the explicit mandates of CCP 2030, you ask and serve this interrogatory - -

"Please review your answers to each set of interrogatories previously served on you in this action. If for any reason any answer is no longer correct and complete, identify the answer and state whatever information is necessary to make it correct and complete as of this date."


In addition to the 35-limit, a party may propound "a supplemental interrogatory" to obtain later-acquired information on matters covered by earlier interrogatories (but not on other topics). [Ca Civ Pro § 2030(c)(8)]

A supplemental interrogatory can be served at least 3 times:
• Twice prior to any trial setting; and
• Once after the initial trial setting (and before the 30-day "cut-off" on discovery proceedings before trial; [Ca Civ Pro § 2030(c)(8)]
• Further, if "good cause" is shown (e.g., lengthy continuances of the trial date), the court may permit more supplemental interrogatories. [Ca Civ Pro § 2030(c)(8)]

Good luck to you - - despite the fact that you're a fish out of water.

IAAL
 

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