2005 California Code of Civil Procedure Sections 2030.210-2030.310 Article 2. Response to Interrogatories

2030.210.  (a) The party to whom interrogatories have been
propounded shall respond in writing under oath separately to each
interrogatory by any of the following:
   (1) An answer containing the information sought to be discovered.
   (2) An exercise of the party's option to produce writings.
   (3) An objection to the particular interrogatory.
   (b) In the first paragraph of the response immediately below the
title of the case, there shall appear the identity of the responding
party, the set number, and the identity of the propounding party.
   (c) Each answer, exercise of option, or objection in the response
shall bear the same identifying number or letter and be in the same
sequence as the corresponding interrogatory, but the text of that
interrogatory need not be repeated.
2030.220.  (a) Each answer in a response to interrogatories shall be
as complete and straightforward as the information reasonably
available to the responding party permits.
   (b) If an interrogatory cannot be answered completely, it shall be
answered to the extent possible.
   (c) If the responding party does not have personal knowledge
sufficient to respond fully to an interrogatory, that party shall so
state, but shall make a reasonable and good faith effort to obtain
the information by inquiry to other natural persons or organizations,
except where the information is equally available to the propounding
party.
2030.230.  If the answer to an interrogatory would necessitate the
preparation or the making of a compilation, abstract, audit, or
summary of or from the documents of the party to whom the
interrogatory is directed, and if the burden or expense of preparing
or making it would be substantially the same for the party
propounding the interrogatory as for the responding party, it is a
sufficient answer to that interrogatory to refer to this section and
to specify the writings from which the answer may be derived or
ascertained.  This specification shall be in sufficient detail to
permit the propounding party to locate and to identify, as readily as
the responding party can, the documents from which the answer may be
ascertained.  The responding party shall then afford to the
propounding party a reasonable opportunity to examine, audit, or
inspect these documents and to make copies, compilations, abstracts,
or summaries of them.
2030.240.  (a) If only a part of an interrogatory is objectionable,
the remainder of the interrogatory shall be answered.
   (b) If an objection is made to an interrogatory or to a part of an
interrogatory, the specific ground for the objection shall be set
forth clearly in the response.  If an objection is based on a claim
of privilege, the particular privilege invoked shall be clearly
stated.  If an objection is based on a claim that the information
sought is protected work product under Chapter 4 (commencing with
Section 2018.010), that claim shall be expressly asserted.
2030.250.  (a) The party to whom the interrogatories are directed
shall sign the response under oath unless the response contains only
objections.
   (b) If that party is a public or private corporation, or a
partnership, association, or governmental agency, one of its officers
or agents shall sign the response under oath on behalf of that
party.  If the officer or agent signing the response on behalf of
that party is an attorney acting in that capacity for the party, that
party waives any lawyer-client privilege and any protection for work
product under Chapter 4 (commencing with Section 2018.010) during
any subsequent discovery from that attorney concerning the identity
of the sources of the information contained in the response.
   (c) The attorney for the responding party shall sign any responses
that contain an objection.
2030.260.  (a) Within 30 days after service of interrogatories, or
in unlawful detainer actions within five days after service of
interrogatories the party to whom the interrogatories are propounded
shall serve the original of the response to them on the propounding
party, unless on motion of the propounding party the court has
shortened the time for response, or unless on motion of the
responding party the court has extended the time for response.  In
unlawful detainer actions, the party to whom the interrogatories are
propounded shall have five days from the date of service to respond
unless on motion of the propounding party the court has shortened the
time for response.
   (b) The party to whom the interrogatories are propounded shall
also serve a copy of the response on all other parties who have
appeared in the action.  On motion, with or without notice, the court
may relieve the party from this requirement on its determination
that service on all other parties would be unduly expensive or
burdensome.
2030.270.  (a) The party propounding interrogatories and the
responding party may agree to extend the time for service of a
response to a set of interrogatories, or to particular
interrogatories in a set, to a date beyond that provided in Section
2030.260.
   (b) This agreement may be informal, but it shall be confirmed in a
writing that specifies the extended date for service of a response.
   (c) Unless this agreement expressly states otherwise, it is
effective to preserve to the responding party the right to respond to
any interrogatory to which the agreement applies in any manner
specified in Sections 2030.210, 2030.220, 2030.230, and 2030.240.
2030.280.  (a) The interrogatories and the response thereto shall
not be filed with the court.
   (b) The propounding party shall retain both the original of the
interrogatories, with the original proof of service affixed to them,
and the original of the sworn response until six months after final
disposition of the action.  At that time, both originals may be
destroyed, unless the court on motion of any party and for good cause
shown orders that the originals be preserved for a longer period.
2030.290.  If a party to whom interrogatories are directed fails to
serve a timely response, the following rules apply:
   (a) The party to whom the interrogatories are directed waives any
right to exercise the option to produce writings under Section
2030.230, as well as any objection to the interrogatories, including
one based on privilege or on the protection for work product under
Chapter 4 (commencing with Section 2018.010).  The court, on motion,
may relieve that party from this waiver on its determination that
both of the following conditions are satisfied:
   (1) The party has subsequently served a response that is in
substantial compliance with Sections 2030.210, 2030.220, 2030.230,
and 2030.240.
   (2) The party's failure to serve a timely response was the result
of mistake, inadvertence, or excusable neglect.
   (b) The party propounding the interrogatories may move for an
order compelling response to the interrogatories.
   (c) The court shall impose a monetary sanction under Chapter 7
(commencing with Section 2023.010) against any party, person, or
attorney who unsuccessfully makes or opposes a motion to compel a
response to interrogatories, unless it finds that the one subject to
the sanction acted with substantial justification or that other
circumstances make the imposition of the sanction unjust. If a party
then fails to obey an order compelling answers, the court may make
those orders that are just, including the imposition of an issue
sanction, an evidence sanction, or a terminating sanction under
Chapter 7 (commencing with Section 2023.010). In lieu of or in
addition to that sanction, the court may impose a monetary sanction
under Chapter 7 (commencing with Section 2023.010).
2030.300.  (a) On receipt of a response to interrogatories, the
propounding party may move for an order compelling a further response
if the propounding party deems that any of the following apply:
   (1) An answer to a particular interrogatory is evasive or
incomplete.
   (2) An exercise of the option to produce documents under Section
2030.230 is unwarranted or the required specification of those
documents is inadequate.
   (3) An objection to an interrogatory is without merit or too
general.
   (b) A motion under subdivision (a) shall be accompanied by a meet
and confer declaration under Section 2016.040.
   (c) Unless notice of this motion is given within 45 days of the
service of the response, or any supplemental response, or on or
before any specific later date to which the propounding party and the
responding party have agreed in writing, the propounding party
waives any right to compel a further response to the interrogatories.
   (d) The court shall impose a monetary sanction under Chapter 7
(commencing with Section 2023.010) against any party, person, or
attorney who unsuccessfully makes or opposes a motion to compel a
further response to interrogatories, unless it finds that the one
subject to the sanction acted with substantial justification or that
other circumstances make the imposition of the sanction unjust.
   (e) If a party then fails to obey an order compelling further
response to interrogatories, the court may make those orders that are
just, including the imposition of an issue sanction, an evidence
sanction, or a terminating sanction under Chapter 7 (commencing with
Section 2023.010).  In lieu of or in addition to that sanction, the
court may impose a monetary sanction under Chapter 7 (commencing with
Section 2023.010).
2030.310.  (a) Without leave of court, a party may serve an amended
answer to any interrogatory that contains information subsequently
discovered, inadvertently omitted, or mistakenly stated in the
initial interrogatory.  At the trial of the action, the propounding
party or any other party may use the initial answer under Section
2030.410, and the responding party may then use the amended answer.
   (b) The party who propounded an interrogatory to which an amended
answer has been served may move for an order that the initial answer
to that interrogatory be deemed binding on the responding party for
the purpose of the pending action.  This motion shall be accompanied
by a meet and confer declaration under Section 2016.040.
   (c) The court shall grant a motion under subdivision (b) if it
determines that all of the following conditions are satisfied:
   (1) The initial failure of the responding party to answer the
interrogatory correctly has substantially prejudiced the party who
propounded the interrogatory.
   (2) The responding party has failed to show substantial
justification for the initial answer to that interrogatory.
   (3) The prejudice to the propounding party cannot be cured either
by a continuance to permit further discovery or by the use of the
initial answer under Section 2030.410.
   (d) The court shall impose a monetary sanction under Chapter 7
(commencing with Section 2023.010) against any party, person, or
attorney who unsuccessfully makes or opposes a motion to deem binding
an initial answer to an interrogatory, unless it finds that the one
subject to the sanction acted with substantial justification or that
other circumstances make the imposition of the sanction unjust.