Before you start
Special interrogatories are questions that are typed up by the opposing party or their attorney. This will be a numbered list of questions that the opposing side asks you to answer. Each numbered question is called an interrogatory.
The title of the form will typically be either special interrogatories or specially prepared interrogatories.
You have 30 days to respond to the interrogatories. If you were served by mail, you typically have 35 days from the date of mailing to respond.
Just below the top caption identifying the case, the form identifies the Answering (or Responding) party. Make sure that this is you. If it lists another party in your lawsuit, you do not need to respond. They are provided for your information.
There is no form for your answer, but you typically have to respond in a specified format, using paper with numbers down the left-hand side, with your name and address at the top left, the name of the court and of the case, and the case number. A sample of this format is included in the steps below.
How to respond to Special interrogatories
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Download the blank response template and fill in basic information
There is no form for your answer, but you typically have to respond in a specified format, using paper with numbers down the left-hand side, with your name and address at the top left, the name of the court and of the case, and the case number. This is called "pleading" paper. You may create pleading paper in your word processor, or download the sample pleading paper captioned and formatted for your answer below:
Complete the top caption with your name, address, and telephone number, the names of the parties in your case, and case number. Copy the name of the Asking Party, Answering Party, and Set Number from the special interrogatories.
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Prepare the template for your responses
The Special Interrogatories you received should have a list of numbered questions. You need to respond to each question in the same order on your response template.
On your template, each question, write “Response to Interrogatory number” followed by the number of the question.
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example
Response to Interrogatory number 1:
Response to Interrogatory number 2:
Response to Interrogatory number 3:
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Read and answer the questions
Before the numbered list of questions, the opposing side may have a list of definitions. Be sure to read these definitions carefully. Whenever one of the defined words appears in an interrogatory in all capital letters, it refers to the definition from this list.
Read each question (interrogatory) very carefully. Answer only the question that is asked, and avoid the temptation to over-explain your answer.
If the question contains several parts, you may break your answer into parts as well.
It is also possible that you might object to the question. To raise an objection, you write “Responding party objects on the grounds” followed by the why you object.
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Sign the document
Once you are done, date and sign under the language “I declare under penalty of perjury under the laws of the State of California that the foregoing answers are true and correct.” By signing, you are stating that your answers are true and you could be prosecuted for perjury if they are not.
This perjury language is called a “verification,” and is required unless your responses contain only objections. For anything other than objections, if this language is missing it is considered the same as not responding at all.
Respond to discovery requests
What's next?
After you complete your response, you’ll need to share your responses with the opposing side. You follow a specific court process to do this called serving papers.