California Personal Injury and Bike Accident Attorney - Discovery; Written Interrogatories

FORM INTERROGATORIES IN PARTICULAR CASES
As you can see, many of these questions would not be asked in a personal injury case. For instance, if the author represents a Plaintiff in a routine motorcycle accident case, the following questions :
1.1 through 4.2
6.1 through 6.7
7.1 through 7.3
12.1 through 16.10
20.0 through 20.11

ANSWERING AND OBJECTING TO FORM INTERROGATORIES
Form interrogatories are mailed to opposing counsel who has thirty-five days to answer or object. Although these are approved form interrogatories, some of them are objectionable (particularly 12.1) and need not be answered by the receiving party if that party makes the appropriate objection.

Some of the objections permitted by the court in answering interrogatories are:
1. The question calls for information not relevant to the subject matter of this action nor to the discovery of admissible evidence

2. The question is overly broad and remote and as such is not calculated to lead to the discovery of information relevant to the subject matter of this action nor to the discovery of admissible evidence. (For instance, in a motorcycle accident case, if the Plaintiff were asked to identify all types of vehicles he has ever been in, in the last ten years, this objection would be made).

3. The question invades Plaintiff's right of privacy, is impermissively overbroad and therefore oppressive, burdensome, and irrelevant to the subject matter of this action in that it seeks disclosure of Plaintiff's medical history which, except as answered, does not relate to the injuries which are the subject of this action

4. To answer this question would result in annoyance, embarrassment, or oppression to Plaintiff in that the question is overly broad indefinite as to time and without reasonable limitation in its scope.

5. Oppressive, harassing and burdensome; the information sought seeks Plaintiff's counsel's legal analysis and theories regarding laws, ordinances, safety orders, etc. that are equally available to Defendant; the question also invades the attorney's work product privilege.

6. The question is boilerplate in form requiring reference back to preceding questions, introductions etc., thus making the question oppressive, burdensome, ambiguous, and unintelligible.

7. The question is oppressive and burdensome because it is vague, ambiguous, and unintelligible so as to make a response impossible without speculation as to the meaning of the question.

8. The question purports to be a "continuing interrogatory" and as such is oppressive and burdensome and is not permitted under California law

9. The question calls for information that is available to all parties equally, and is therefore oppressive and burdensome to Plaintiff.

10. The question seeks information that is protected from disclosure by the attorney's work product privilege

11. The question seeks to invade Plaintiff's counsel's work product privilege in that it calls for him to provide an analysis of written data.

12. Asked and answered in prior interrogatories.

13. Attorney-client privilege protects disclosure of the information sought

14. The question calls for a professional opinion from a lay witness; consequently the question is oppressive, harassing and without a foundational showing of competence.

15. This request is not full and complete in and of itself and impermissibly contains subparts or a compound, conjunctive, or disjunctive.