The most important interrogatory in California is Form Interrogatory 15.1. Propound it; meet and confer on it; file motions to compel on it. Make them give you their facts, witnesses, and documents supporting their denials and affirmative defenses. Form Interrogatory 15.1 is the great equalizer in California trust and probate litigation.

  • Kathie

    Excellent and informative! Thank you for taking the time to clarify a confusing and daunting aspect of litigation.

  • Michael

    You might want to review Rutter Group, Cal.Prac.Guide Civ. Pro. Before Trial, on the section about the form roggs you can object to, to which 15.1 is one of them.

  • You can always make a “valid” objection to any interrogatory. That’s not the issue I addressed regarding 15.1. The problem is with blanket or disingenuous objections where a defense attorney attempts to avoid answering 15.1 at all. A defendant must provide all facts, all witnesses who know about those facts, and all documents that support those facts for its general denial and/or all affirmative defenses.