§ 2030.050.Propounding more than 35 specially prepared
Title 4. Civil Discovery Act · Chapter 13. Written Interrogatories · Article 1. Propounding Interrogatories · Last amended 2005 · Last verified July 29, 2026
Full Text of § 2030.050
Plain-English Summary
This section supplies the actual language a party must use to invoke the Section 2030.040 grounds for exceeding the 35-interrogatory cap. Rather than leaving the required showing to each attorney's own phrasing, the statute sets out a model declaration nearly word for word, to be signed under penalty of perjury by the party or the attorney propounding the interrogatories, and attached to every set that pushes the running total past 35.
The declaration has to do real work, not just recite boilerplate. It must identify how many interrogatories, form and specially prepared, have already gone to this particular responding party, state how many specially prepared interrogatories the current set adds, confirm that the declarant is familiar with the case and has personally reviewed each question in the set, and then state which of the Section 2030.040 grounds applies and why, tied to the facts of the specific lawsuit rather than the statutory language alone. It closes with an assurance that no question is being asked for an improper purpose such as harassment or needless delay. A declaration that skips the case-specific explanation invites exactly the protective-order challenge Section 2030.040 anticipates.
Frequently Asked Questions
When must the Section 2030.050 declaration be attached to a set of interrogatories?
Whenever a party is propounding, or has propounded, more than 35 specially prepared interrogatories to the same party.
What must the declaration state about the reason for exceeding the limit?
It must identify which factor from Section 2030.040 the propounding party relies on and explain why that factor applies to the particular lawsuit, not just recite the statutory language.
Does the declaration have to disclose how many interrogatories were previously served?
Yes. It must state the total number of interrogatories previously propounded to the party and how many of those were not official form interrogatories.
Is the declaration signed under penalty of perjury?
Yes. The statutory form concludes with a declaration under penalty of perjury under California law.
Amendment History
(Added by Stats.2004, c. 182 (A.B.3081), § 23, operative July 1, 2005. Amended by Stats.2005, c. 22 (S.B.1108), § 22.)