These sample special interrogatories for California are drafted as contention interrogatories and can be easily modified. The sample is very detailed, has been revised and updated as of March 2018, is 16 pages including the declaration for additional discovery and proof of service by mail. What are contention interrogatories in California? An interrogatory is not objectionable because an answer to it involves an opinion or contention that relates to fact or the application of law to fact, or would be based on information obtained or legal theories developed in anticipation of litigation or in preparation for trial.

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