§ 2030.210.Form and content of response

This section supplies the basic architecture every response to interrogatories has to follow. Each interrogatory gets its own separate response, and that response can only take one of three forms: an answer supplying the information sought, an exercise of the option under Section 2030.230 to point to underlying business records instead of writing out an answer, or an objection to that particular interrogatory. The response's caption has to identify the responding and propounding parties and the set number, and each answer, option, or objection must carry the same number or letter as its corresponding interrogatory, in the same order, though the interrogatory's own text does not have to be repeated unless the electronic-exchange rule below applies.

Subdivision (d) modernizes the exchange process for parties who want it. On request, the propounding party must supply the interrogatories themselves in electronic format within three court days, and the responding party must reciprocate with the responses in electronic format within three court days of a request made after the responses are served. The parties can agree on whatever file format and transmission method they like; absent agreement, the fallback is plain text sent by email to an address the requesting party supplies. A party need not create an electronic version of something that never existed in that format. And a responding party who receives the interrogatories electronically under this process has to include the actual interrogatory text immediately before its answer, so the electronic response reads as a self-contained document.