Can California Law Mandate Documents for Interrogatory Answers?

Question from Bey, Can California Law Mandate Documents for Interrogatory Answers?

Answer from AI:

Legal Framework for Interrogatories in California

California’s discovery rules are set out in the California Code of Civil Procedure (CCP), §§ 2030.210‑2030.310. Interrogatories are written questions that one party serves on the other, and the responding party must answer in writing, under oath, and within 30 days (CCP 2030.260).

When Document Support Is Required

• CCP 2030.290 expressly permits a responding party to be required to produce documents that “support the answer” to an interrogatory.
• The rule applies when a simple “yes” or “no” is insufficient to convey the factual basis of the answer, or when the answer references a calculation, a transaction, or a factual assertion that can be verified by a record.
• Courts routinely enforce this requirement. For example, in Miller v. Superior Court (1999) 71 Cal.App.4th 1245, the appellate court held that a party’s answer to an interrogatory about “the amount of damages claimed” must be accompanied by the underlying billing statements and settlement calculations.

Common Types of Document Support

Interrogatory Topic	Typical Supporting Documents
Medical expenses	Itemized bills, insurance statements, medical records
Lost wages	Recent pay stubs, employer’s wage‑loss certification, tax returns
Contractual relationships	Signed contracts, invoices, correspondence
Property ownership	Deeds, title reports, registration certificates

If the responding party cannot produce the requested documents, they must state the reason (e.g., privilege, loss, or that the documents do not exist) and may attach a privilege log where appropriate.

Sample Interrogatory Set

Below is a sample set that illustrates how a party can request both factual answers and supporting documentation. The interrogatories are numbered for clarity; a real pleading would include a proper caption and verification clause.

1. Identify each person who witnessed the incident described in the complaint, and state the address, telephone number, and relationship (if any) to any party.
2. Describe in detail the events that occurred on [date] at [location], including the actions of each party and any statements made.
3. State the make, model, year, and Vehicle Identification Number (VIN) of every vehicle involved, and identify the registered owner of each vehicle at the time of the incident.
4. List all medical providers who treated you for injuries arising from the incident, and for each provider state the dates of treatment, diagnoses, and the total amount billed.
   Produce copies of all medical bills, itemized statements, and any settlement offers received.
5. State the total amount of wages you claim to have lost as a result of the incident, and describe the method used to calculate that amount.
   Attach your most recent three pay stubs, a written statement from your employer confirming the wage loss, and any tax documents used in the calculation.
6. Identify any insurance policies that may provide coverage for the claims asserted in this action, including the insurer’s name, policy number, limits, and the dates of coverage.
   Produce a copy of each policy and any correspondence with the insurer regarding this claim.
7. State whether you have made any payments to the plaintiff or any third party in connection with the incident.
   If “yes,” attach copies of cancelled checks, receipts, or settlement agreements.

Objections and Limitations

• Overbreadth / Undue Burden – A party may object if the request seeks information that is not reasonably calculated to lead to the discovery of admissible evidence.
• Privilege – Documents protected by attorney‑client privilege or work‑product doctrine must be identified on a privilege log, not simply withheld.
• Relevance – Under CCP 2017.010, discovery must be “relevant to any party’s claim or defense.” Irrelevant interrogatories can be struck.

Practical Tips for Responding

1. Answer Fully and Truthfully – Provide the best information available; vague or incomplete answers can lead to motions to compel.
2. Verify the Answers – A verification statement under penalty of perjury is required (CCP 2030.250).
3. Attach Supporting Documents – When a document is requested, attach it as an exhibit and reference it in the answer (e.g., “See Exhibit A”).
4. Document Any Inability to Produce – If a document is lost, destroyed, or otherwise unavailable, state the reason and describe any efforts made to locate it.

When to Seek Professional Guidance

The rules governing interrogatories and document production can be complex, especially when issues of privilege, confidentiality, or large volumes of records arise. Consult a licensed California attorney to tailor interrogatories to your case, to evaluate objections, and to ensure compliance with all procedural deadlines.

For the full statutory text, see the California Code of Civil Procedure, §§ 2030.210‑2030.310 (available at the California Legislative Information website).