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Focus (Forum & Focus)

Nov. 16, 2007

Ruling on Common Objections to Form Interrogatories

Forum Column - By Richard M. Coleman - The "Musings of a Discovery Referee" series continues with another insight into a common mistake.

FORUM COLUMN

By Richard M. Coleman

      Discovery disputes often involve the use of form interrogatories. In this situation, one party objected to Form Interrogatory 15.1, as follows: "Form Interrogatory 15.1 violates CCP section 2030.060 (d) as not being 'complete in of itself' because it refers to [Movant's] denials and affirmative defenses in [Movant's] pleadings without setting them forth in the Interrogatory."
  ...

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