§ 2030.240.Partial objection to interrogatory; statement of grounds for

An objection to one part of an interrogatory does not excuse a non-answer to the whole thing. This section requires that when only a portion of an interrogatory is objectionable, the responding party still has to answer the remainder, an all-or-nothing refusal is not permitted just because some piece of the question triggers a valid objection.

Where an objection is made, whether to a whole interrogatory or to part of one, subdivision (b) requires more than a bare assertion. The specific ground for the objection has to be set out clearly in the response itself, so the propounding party and the court can evaluate it without guessing what the objecting party means by it. Two categories get singled out for extra specificity: an objection resting on privilege has to clearly identify which particular privilege is being invoked, attorney-client privilege, physician-patient privilege, or another, rather than gesturing vaguely at privilege in general, and an objection resting on the work-product protection has to expressly assert that claim by name. Both requirements exist so that a later motion to compel a further response, or a privilege log dispute, does not have to untangle what an ambiguous objection was trying to protect in the first place.