§ 2030.230.Answers specifying writings from which answer may be derived or

Some interrogatories, particularly ones asking a party to total up transactions, summarize a document set, or reconstruct a history from business records, effectively ask the responding party to do research and analysis rather than recall a fact. This section gives a responding party an alternative to doing that work when it would be no more burdensome for the propounding party to do it directly: instead of preparing the compilation, abstract, audit, or summary itself, the responding party can identify the specific writings from which the answer could be derived and let the propounding party do the compiling.

Two conditions have to be satisfied before this option is available. First, the burden or expense of preparing the compilation must be substantially the same for the party asking the question as for the party answering it, an option built for situations of roughly equal access and effort, not a way to dump a lopsided research burden onto the other side. Second, the specification of records has to be detailed enough that the propounding party can locate and identify the relevant documents just as readily as the responding party could, a vague pointer to "our files" does not satisfy this section. Once those conditions are met and the specification given, the responding party then has to give the propounding party a reasonable opportunity to examine, audit, or inspect the identified records and to make its own copies, compilations, or summaries from them.