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.
"Form Interrogatory 15.1"
Give me your facts: Why Form Interrogatory 15.1 is the most important discovery question in California
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California Form Interrogatory 15.1 (an “interrogatory” is just a question) is the most important interrogatory to serve on your opposing party in a lawsuit. And the law requires they answer it fully and completely. Yet, so many attorneys refuse to answer the question properly.
A typical use of 15.1 follows:
You file a Trust Contest…