Use Special Interrogatories to request information

Use Special Interrogatories when you want to gather information from the other side by having them answer questions you write yourself. 

Before you start

Use a Special Interrogatory (sometimes called a Specially Prepared Interrogatory) if you want to write the questions yourself. You use this if you want to ask questions that are specific to your case and are not included on the Form Interrogatory form.

A Special Interrogatory doesn't use a specific court form. You must create it yourself using a template.

  • If you contend the PLAINTIFF's vehicle was moving at the time of the motor vehicle collision that is the subject of this case state the speed of said vehicle to the best of your recollection.
  • Describe by date and amount the last payment you allege the defendant made toward the account alleged in your complaint.
  • If you contend that your tree falling onto plaintiff’s property did not cause any damage, state all facts that support that contention.

How to use Special Interrogatories

  • Download a template for Special Interrogatories

    There are many different templates available for Special Interrogatories. You can get a template from your local law library, or use the simple template below. In the template below, replace the text contained in [brackets] with your questions and delete the brackets.

  • Fill out basic information at the top

    A few definitions of terms that may help when you fill out the top of the template: 

    • The person who started the case is the plaintiff, the person responding to the case is the defendant.  

    • You are the Asking Party. The other side is the Answering Party

    • Set No. refers to the number of times you’ve sent interrogatories. Write “one” if this is the first time. 

  • Add your own definitions (if useful)

    The first page has a definitions. These definitions tell the person answering that any time they see this term in the questions (in uppercase letters) it should be defined as it is in the list of definitions. 

    Feel free to use them if they are useful for you, or delete them if they are not. Add your own definitions in the same format.

  • Write your questions (interrogatories)

    Write your interrogatories in a list as shown in the template. Add each one as a numbered item.

    You can write interrogatories in the form of a question such as:

    1. How much did you pay to have your vehicle repaired after the collision in the Complaint?

    1. When did you last make a payment to the plaintiff?

    1. Who witnessed the agreement being made between the plaintiff and defendant?

    Or you can write them in the form of an instruction to provide information such as: 

    1. List all payments that you made to the account described in the Complaint

    1. Identify all documents that support your contention that you suffered a specific dollar amount of damages.

    1. State in detail the facts that support your contention that the asking party is responsible for the motor vehicle collision described in the Complaint.

    For interrogatories, action words such as “list,” “describe,” “identify,” or “state” are very useful.

    You may ask the other side to identify a document but you cannot use this form of discovery to get them to give it to you. Requesting documents requires a different kind of discovery process. 


    If your case is a limited civil case ($35,000 or less) you can request up to a total of 35 combined request for admissionsform interrogatories , special interrogatories, and requests for production

    If your case is an unlimited civil case (over $35,000) you may ask up to 35 special interrogatories, but may ask more with a declaration explaining the need for additional requests and a statement that the request is not done for an improper purpose. A Declaration (form MC-030) may be  used, with the template language contained in Code of Civil Procedure Section 2030.050 and the reason it is permitted under Code of Civil Procedure Section 2030.040.
  • Sign and date the document

    When you are done, sign and write the date at the end of the document.

  • Make copies

    Make a copy of your Special Interrogatories document for each attorney or self-represented party in your case. You will keep the original. They are not filed with the court.

Discovery from a party in your case

What's next?

Once you’ve completed the form, you’ll serve it by mail to the other attorneys or self-represented parties.

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