Objections to Form Interrogatories

Just a few hours after posting my white paper on written discovery, I encountered this post at Storm's Employment Law, criticizing the abuse of form interrogatories and raising the issue whether these interrogatories -- approved by the California Judicial Council -- can be objected to.  Actually, it seems quite clear that they can be objected to just like any other inappropriate interrogatories.  The Court of Appeal held in Nacht & Lewis Architects, Inc. v. Superior Court (1996)  47 Cal.App.4th 214 that Form Interrogatories 12.2 and 12.3 (asking for names of persons from whom a party has taken statements) violate the attorney client privilege and work product doctrine.

Comments

[jonerikstorm]

Thanks for the link and the citation!

I think I've come across that decision--or a similar one--in the past, but just as a thought exercise to shoot down the concept that they were "bullet proof" I posited the attorney-client privilege issue.

I look forward to reading your paper.

Regards,

Jon-Erik

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