contention interrogatories with an exhaustive recitation of evidence would be improper, inconsistent with the case law and unduly burdensome and prejudicial, for at least three reasons. First, Complaint Counsel objected to Respondents’ interrogatories as overly broad and

ates that an interrogatory is not objectionable because it asks for an opinion or contention that relates to fact or the application of law to fact.

“Contention interrogatories are premature if a propounding party cannot present plausible grounds showing that early answers to contention questions will efficiently advance litigation, or if the [answering party] does not have adequate information to assert its position.” Contention interrogatories are special that is designed to obtain information as to whether the opposing party will make a certain contention, and the facts and other evidence on which that contention is based. An interrogatory may relate to whether another party is making a certain contention, or to the facts, witnesses, and writings on which a The Limits on Contention Interrogatories There are important limits to contention interrogatories: 1.A party can only discover whether its adversary is “making a certain contention, or to the facts, witnesses, and writings on which a contention is based.” (Code Civ. Proc. § 2030.010(b).) By definition, this does not permit a party to request a list of 2018-02-20 In addressing this argument on a motion to compel, the court noted that contention interrogatories "seek to clarify the basis for or scope of an adversary's legal claims." They are not objectionable "merely because [they] ask[] for an opinion or contention that relates to fact or the application of law to fact." Contention Discovery. Discovery has just opened in your case and your client receives interrogatories. Within those interrogatories are some asking “state the facts upon which you intend to rely at trial to demonstrate plaintiff’s medical injuries are not causally related to the accident.”. 2009-05-12 Contention Interrogatories: , the rule thatprovides parties may Finally serve contention not interrogatories, which are inquiries intended to enable parties to learn other parties’ positions with Contention interrogatories highlight the critical role of timing in the work product doctrine context.

No one would expect a court to order litigants to answer such interrogatories early in the discovery process, but at some point every litigant obviously must disclose its contentions. contention interrogatories can be almost mindlessly generated, can be used to impose great burdens on opponents, and can generate a great deal of counterproductive friction between parties and counsel.” But note the adjective “early.” It isn’t so much that contention interrogatories are per se abu-sive—it’s that they are usual- RESPONSE TO CONTENTION INTERROGATORY NO.1: Palmdale objects to this interrogatory on the grounds that it is vague and ambiguous as to the meaning of "hydrologically connected," particularly in relation to propert.-2-P6399-1234\1078954vl.doc Response to Contention Interrogatories (Set One) Use “contention interrogatories” to obtain the facts, witnesses, and documents the plaintiff will rely on to support their claims against your client. Many plaintiff’s attorneys will object to these based on privilege grounds or that the request is premature. This sometimes is permitted under Federal Rule of Civil Procedure 33 (d). But the Safety Today court said no, a plaintiff could not use the Rule 33 (d) mechanism to "identify" its trade secrets in response to a contention interrogatory.

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An interrogatory may inquire whether a party makes a specific legal or factual contention and may ask the responding party to state the legal theories and to describe in general the factual bases for the party's claims or defenses, but interrogatories may not be used to require the responding party to marshal all of its available proof or the proof the party intends to offer at trial.

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Discovery has just opened in your case and your client receives interrogatories.

The interrogatory should be Contention Discovery. July 16, 2012.
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e. special interrogatories .. 47 f. juror questions to witnesses .. 48 x. judgment .. 49 a. motions to vacate..

SPECIAL INTERROGATORY NO. 3: Please state the name and address of YOUR employer, your position and duties, and your wages at the time of the SUBJECT INCIDENT and at the present time. SPECIAL INTERROGATORY NO. 4: Contention Interrogatories In Trade Secret Cases Demand Strict Compliance Yesterday, I gave a lengthy presentation to the American Intellectual Property Law Association's Trade Secrets Committee. The bulk of my presentation dealt with the knotty issue of properly identifying trade secrets in litigation.

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Sep 8, 2010 Compelling meaningful responses to contention interrogatories seeking the basis for a party's contentions in its complaint or affirmative

Contention Interrogatories. As the name suggests, these interrogatories seek to find out what the patent holder contends. They are critical for forcing the patent holder to identify the basis of its case before trial so that you can develop your case and seek the appropriate discovery. 1. Infringement Contentions. For contention interrogatories, you ask the other party to provide information relating to contested statements the other side has made, such as in the petition or response to the petition. You can find our firm’s template for contention interrogatories by clicking the link in this sentence.

Contention Discovery. Discovery has just opened in your case and your client receives interrogatories. Within those interrogatories are some asking “state the facts upon which you intend to rely at trial to demonstrate plaintiff’s medical injuries are not causally related to the accident.”.

2015-08-12 Contention interrogatories can be characterized as: “any question that asks another party to indicate what it contends . . . [a question asking] another party whether it makes some specified contention . . . [a question asking] an opposing party to state all facts on which it bases some specified contention .

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