Sample Special Interrogatories to Plaintiff

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This sample special interrogatories to plaintiff is for a California civil case and is intended to be used by a defendant but can be modified for u... (More) This sample special interrogatories to plaintiff is for a California civil case and is intended to be used by a defendant but can be modified for use by a plaintiff.

The document is very detailed and is 33 pages including the declaration for additional discovery and proof of service by mail. There are 195 special interrogatories, based on a complaint with 65 paragraphs. The sample can be modified to add or subtract interrogatories as needed.

The author is a freelance paralegal with over 15 years of experience in California civil litigation and has used this sample for many years. Note that the author is NOT an attorney and no guarantee or warranty is provided. (Less)