How many times can you propound supplemental discovery in California?

(b) A party may propound a supplemental interrogatory twice before the initial setting of a trial date, and, subject to the time limits on discovery proceedings and motions provided in Chapter 8 (commencing with Section 2024.010 ), once after the initial setting of a trial date.

When can you propound discovery in California?

(a) A defendant may propound interrogatories to a party to the action without leave of court at any time. (b) A plaintiff may propound interrogatories to a party without leave of court at any time that is 10 days after the service of the summons on, or appearance by, that party, whichever occurs first.

Who can propound discovery in California?

The law in California states that a defendant may propound requests for admission at any time, however a plaintiff may not do so until at least ten (10) days have passed since service of the summons on the defendant, or the general appearance by the defendant, whichever occurs first.

How do you propound interrogatories?

(a) A party propounding interrogatories shall number each set of interrogatories consecutively. (b) In the first paragraph immediately below the title of the case, there shall appear the identity of the propounding party, the set number, and the identity of the responding party.

Do you have to verify supplemental discovery responses?

Each supplemental or further response and each amended answer must be identified by the same number or letter and be in the same sequence as the corresponding interrogatory, inspection demand, or admission request, but the text of the interrogatory, demand, or request need not be repeated.

Is there a duty to supplement discovery responses in California?

Unlike Federal Rule Civil Procedure 26(e)(1) – (2), California law does not impose a continuing duty on a party to supplement their interrogatory or document responses.

How many days do you have to respond to discovery in California?

30 days
You have 30 days after the form or special interrogatories were served to you (35 days if served by mail from within California) to serve your responses to the interrogatories.

Are contention interrogatories allowed in California?

Thus, contention interrogatories are permitted, despite work product doctrine, because the statutes and case law permit them.

What does propounding discovery mean?

Propounding and Responding to Written Discovery. Requests for Admissions. Requests for admissions (“RFA”) are used to ask another party to admit that certain facts are true, or that certain documents are authentic, so that these facts do not need to be proven or documents authenticated at trial.

Does California serve discovery before answer?

[CALIFORNIA CODE OF CIVIL PROCEDURE § 1985.6(b)(2) & (3).] Must be served on records custodian 15 days before date of production. Respond to Written Discovery – 30 days (+5 days if questions were mailed). Practical Last Day to Serve Discovery (and be able to make a motion on it) – 90-100 days before trial.

What is a special interrogatory in California?

A party to a lawsuit uses interrogatories to obtain information in discovery from another party to the lawsuit. A party may serve: Special interrogatories, which are specially prepared by the propounding party’s attorney (see Drafting Note, Special Interrogatories).