§ 2030.010.Scope of discovery; restrictions

This section opens the written-interrogatories chapter with the basic grant of authority: any party may propound written interrogatories, answered under oath, to any other party, subject to the general scope-of-discovery rules and the restrictions that apply across all discovery methods. Nothing here limits interrogatories to simple, factual questions. Subdivision (b) says so directly by naming the interrogatory type that draws the most resistance in practice, the contention interrogatory, which asks whether a party is making a particular claim or defense and, if so, what facts, witnesses, and documents support it.

A party on the receiving end of a contention interrogatory often wants to object that the question calls for an opinion, a legal conclusion, or work product developed while preparing for trial. Subdivision (b) forecloses that objection by name. An interrogatory does not become improper just because a complete answer requires the responding party to apply law to fact, offer an opinion about a disputed issue, or draw on information or legal theories developed in anticipation of litigation. That does not strip away every other objection a party might have, undue burden, privilege, and vagueness objections still apply on their own terms, but it means a party cannot dodge a contention interrogatory on the theory that answering it requires thought rather than simple recitation of facts.