"Specially Prepared Interrogatories"

As every lawyer is aware, a party may propound more than 35 specially prepared interrogatories or requests for admissions simply by attaching a Declaration of Necessity pursuant to C.C.P. §2030.040 and C.C.P. §2033.040 stating the reasons why they need more. See C.C.P. §2030.050 and C.C.P. §2033.050. However, when you receive more than 35 specially prepared interrogatories or requests for admissions, you should ask yourself the question “IS IT REALLY NECESSARY?”
Continue Reading