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Civil Litigation

California Special Interrogatories

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About This Template

Beyond the standard Form Interrogatories, detailed case investigation often requires highly specific questions. This template provides a compliant framework for drafting Special Interrogatories for use in California Superior Courts. It allows litigation firms to efficiently draft custom questions relevant to the unique facts of a case while ensuring compliance with the CCP's format and numbering limitations. This tool maximizes the effectiveness of custom discovery while maintaining procedural compliance.

Special Interrogatories

Jurisdiction Notes

This template is subject to the strict rules of the California Code of Civil Procedure (CCP $S$ 2030.010 et seq.). Attorneys must be meticulous about the rule of 35 (limiting specially prepared interrogatories to 35, unless a Declaration of Additional Discovery is used). The instructions and definitions section must be compliant, and the interrogatories must not be "compound" or "contention" questions without proper foundation. Failure to comply can result in the requests being stricken by the court.

What is this template?

This is a formal discovery document used in California civil litigation to ask specific, written questions that are not covered by the standard Judicial Council Form Interrogatories. The Special Interrogatories template provides the necessary formatting, instructions, definitions, and the structured numbering required by the California Code of Civil Procedure (CCP). It is designed to be served on an opposing party to elicit specific factual information relevant to the claims and defenses in the lawsuit.

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.