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Civil Litigation

California Plaintiff's Special Interrogatories - Personal Injury

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About This Template

Effective discovery is crucial to proving liability and damages in a personal injury case. This template offers a targeted set of Plaintiff's Special Interrogatories focused specifically on California personal injury matters. It allows litigation firms to quickly draft custom questions covering key areas such as accident causation, defendant negligence, witness identification, and insurance coverage. This specialization boosts firm efficiency by providing highly relevant questions without exceeding California's discovery limits.

Plaintiff's Special Interrogatories - Personal Injury

Jurisdiction Notes

This template is strictly governed by California Civil Discovery Act (CCP $S$ 2030.010 et seq.). Attorneys must diligently count the questions, ensuring the total number of specially prepared interrogatories does not exceed the limit of 35 per party unless the required declaration is attached. Furthermore, the requests must be narrowly tailored to the facts of the personal injury case to withstand objections of being overly broad or unduly burdensome under California case law.

What is this template?

This is a formal discovery document containing custom-drafted, written questions served by the plaintiff’s attorney on the defendant in a California personal injury action. The Plaintiff's Special Interrogatories template focuses on essential PI topics, including the details of the accident, the defendant’s defenses, the extent of insurance coverage, and the factual basis for any allegations of comparative fault. It is designed to comply with the formatting rules of the California Code of Civil Procedure (CCP).

How to Customize

With Clio Draft

If this template is available in your region, you can activate it in your Clio Draft account. It will then be pre-filled with information from your contacts and matters, helping you save time.

  1. Click Request Template, and complete the Request Information form.
  2. Open the activation email to activate the template in Clio Draft.
  3. In Clio Draft, go to Library and select the Court forms subtab.
  4. Select a category to view all the court forms associated with that category.
  5. Find the form that you need. You can use the search bar to search by form number or form title.
  6. Click the Actions dropdown and then select Create form template.
  7. At this stage, you can configure any fields on the template that will remain consistent across multiple matters and specific practice areas.
    • Purple fields: These fields are highlighted in purple because they are connected to linked fields that will automatically insert information entered on the Populate page. If you fill in a purple field, the data in that field will always populate when you draft a document from this form template and will not be overwritten by text entered on the populate page.
    • Blue fields: These fields are highlighted in blue because they are unique to a specific matter. You will enter this information after you generate the form template, on the Populate page.

For detailed instructions for drafting form templates and more information about Clio Draft, see Clio Draft: Form Templates and Clio Draft: Draft and Manage Documents.