How do I respond to written discovery, such as interrogatories, in a California personal injury lawsuit?
To respond to interrogatories, you must provide written, truthful answers under oath and any legal objections to the questions within 30 days of when they were served.
Here is how to respond to written interrogatories in a California personal injury case:
Step 1: Calendar Your Deadline
Immediately calculate and calendar your response deadline. Under California Code of Civil Procedure § 2030.260, you have 30 days from the date the interrogatories were served. If they were served by mail from within California, you get an additional 5 calendar days. Missing this deadline can waive your right to object to improper questions.
Step 2: Gather Responsive Information
Systematically collect all information and documents needed to answer the questions. This includes police reports, medical bills, treatment records, photographs, and any communications related to your injury and damages. Your answers must be based on all information reasonably available to you.
Step 3: Draft Your Answers
For each interrogatory, provide a straightforward and truthful answer. If you do not have the information after a reasonable search, you may state that. Be complete and accurate, but do not volunteer information that was not specifically asked.
Step 4: Identify and State Objections
Review each question to see if it is improper. If a question asks for privileged information (like conversations with your attorney), is harassing, or is not relevant to the case (as defined by CCP § 2017.010), you must state a specific legal objection instead of providing an answer. If you fail to object, you may be forced to answer later.
Step 5: Verify and Serve Your Response
You must sign a verification page under penalty of perjury, swearing that your answers are true and correct to the best of your knowledge. Your attorney, if you have one, will sign the document as well to attest to any objections. Serve a copy of the complete, signed response on the opposing party's attorney by the deadline.
Important considerations: Your duty to respond truthfully is absolute, and false answers can be used against you and may constitute perjury. You must conduct a reasonable and good faith effort to obtain the information needed to answer.
Note: Failing to respond or providing incomplete answers can result in the other party filing a "motion to compel" with the court, which could lead to monetary sanctions against you.
This is general information and does not constitute legal advice. For complex situations, consult with a qualified California attorney.
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This information is for general guidance only and should not be considered as legal advice. Please consult with a qualified attorney for specific legal matters.
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Updated: August 13, 2025
Personal Injury
Accident claims, medical malpractice, and compensation rights
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