Response to Interrogatories

Code of Civil Procedure Part 4, Title 4, Chapter 13, Article 2 deals with responses to interrogatories under the Civil Discovery Act.

Section 2030.210 requires the party to whom interrogatories have been propounded to respond in writing under oath separately to each interrogatory by any of the three specified means. In the first paragraph of the response immediately below the title of the case, there appears the identity of the responding party, the set number, and the identity of the propounding party.

Section 2030.220 requires each answer in a response to interrogatories to be as complete and straightforward as the information reasonably available to the responding party permits.

Section 2030.230 provides that, if the answer to an interrogatory would necessitate the preparation or the making of a compilation, abstract, audit, or summary of or from the documents of the party to whom the interrogatory is directed, and if the burden or expense of preparing or making it would be substantially the same for the party propounding the interrogatory as for the responding party, it is a sufficient answer to that interrogatory to refer to this section and to specify the writings from which the answer may be derived or ascertained.

Section 2030.240 requires the remainder of the interrogatory to be answered if only a part of an interrogatory is objectionable. If an objection is made to an interrogatory or to a part of an interrogatory, the specific ground for the objection must be set forth clearly in the response.

Section 2030.250 requires the party to whom the interrogatories are directed must sign the response under oath unless the response contains only objections. The attorney for the responding party signs any responses that contain an objection.

Section 2030.260 requires, within 30 days after service of interrogatories, the party to whom the interrogatories are propounded to serve the original of the response to them on the propounding party, unless on motion of the propounding party the court has shortened the time for response, or unless on motion of the responding party the court has extended the time for response.

Section 2030.270 allows the party propounding interrogatories and the responding party may agree to extend the time for service of a response to a set of interrogatories, or to particular interrogatories in a set, to a date beyond that provided in law. This agreement may be informal, but it must be confirmed in a writing that specifies the extended date for service of a response.

Section 2030.280 prohibits the interrogatories and the response from being filed with the court.

Section 2030.290 provides that, if a party to whom interrogatories are directed fails to serve a timely response, the specified rules apply.

Section 2030.300 allows the propounding party to move for an order compelling a further response if the propounding party deems that any of the three specified circumstances apply. A motion must be accompanied by a meet and confer declaration.

Section 2030.310 states that a party may serve an amended answer to any interrogatory that contains information subsequently discovered, inadvertently omitted, or mistakenly stated in the initial interrogatory. At the trial of the action, the propounding party or any other party may use the initial answer, and the responding party may then use the amended answer.

The party who propounded an interrogatory to which an amended answer has been served may move for an order that the initial answer to that interrogatory be deemed binding on the responding party for the purpose of the pending action. This motion must be accompanied by a meet and confer declaration. The court is required to grant a motion if it determines that all of the three specified conditions are satisfied.