§ 2030.060.Form and content of interrogatories

This section governs the mechanics of drafting a set of interrogatories rather than their substance. Sets must be numbered consecutively so a court and the parties can track how many rounds have gone back and forth, and the caption of each set must identify who propounded it, which numbered set it is, and who must respond. Within a set, each interrogatory needs its own number or letter, and every interrogatory has to stand on its own, fully answerable without cross-referencing a preface, instructions, or another question, unless that preface has been separately approved as part of an official form under Chapter 17.

Two restrictions here get litigated often. Any term the drafter specially defines within the set must appear capitalized every time it is used, so the responding party always knows when a defined meaning is in play. And a specially prepared interrogatory cannot bury multiple questions inside one, no subparts, and no compound, conjunctive, or disjunctive phrasing that forces several distinct inquiries into a single numbered item, a rule aimed squarely at the drafting trick of disguising 100 questions as 35. Finally, subdivision (g) forecloses continuing interrogatories: a party cannot draft a question so that a correct, complete answer given today automatically has to be updated later as new information comes in.