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

In a trip and fall case, it is usually necessary to ask more than thirty-five special interrogatories. In that case the propounder of the interrogatories must sign the following declaration to ask more than the allotted thirty-five questions:
I, (name of attorney) declare:
1. I am presently the attorney for ______, a party to this action.

2. I am propounding to ____ the attached set of interrogatories.

3. This set of interrogatories will cause the total number of specially prepared interrogatories propounded to the party to whom they are directed to exceed the number of specially prepared interrogatories permitted by paragraph (1) of subdivision (c) of the California Code of Civil Procedure.

4. I have previously propounded a total of ____ interrogatories to this party, of which ____ interrogatories were not official form interrogatories.

5. This set of interrogatories contains a total of ____ specially prepared interrogatories.

6. I am familiar with the issues and the previous discovery conducted by all of the parties in the case.

7. I have personally examined each of the questions in this set of interrogatories.

8. This number of questions is warranted under paragraph (2) of subdivision (c) of the California Code of Civil Procedure because ____. (Here state each factor described in paragraph (2) of subdivision (c) that is relied on, as well as the reasons why any factor relied on is applicable to the instant lawsuit.
a. The complexity or the quantity of the existing and potential issues in the particular case.
b. The financial burden on a party entailed in conducting the discovery by oral deposition.
c. The expedience of using this method of discovery to provide to the responding party the opportunity to conduct an inquiry, investigation, or search of files or records to supply the information sought.

9. None of the questions in this set of interrogatories is being propounded for any improper purpose, such as to harass the party, or the attorney for the party, to whom it is directed, or to cause unnecessary delay or needless increase in the cost of litigation.

I declare under penalty of perjury under the laws of California
that the foregoing is true and correct, and that this declaration was
executed on ____. ______________(Signature)
Attorney for

Written questions only go so far. After receiving answers to written interrogatories, the depositions of parties and witnesses normally follow.