discovery responses

FROG responses

Verified answers to Form Interrogatories served by opposing counsel within the statutory 30-day deadline.

When it's used

Within 30 days of service of Form Interrogatories, unless the parties have stipulated to an extension.

Definition

FROG responses are the client’s verified, sworn answers to the Judicial Council DISC-001 Form Interrogatories propounded by opposing counsel, prepared in compliance with California CCP §2030.210 et seq. The paralegal drafts the responses by interviewing the client, gathering supporting documents, and translating the client’s factual account into precise interrogatory language that is complete, non-evasive, and consistent with the documents produced. Each response must be verified by the client under penalty of perjury, and any objections—privilege, burden, or relevance—must be stated with specificity or they are waived. The paralegal calendars the 30-day deadline from the date of service and tracks any meet-and-confer communications needed to resolve disputes over the sufficiency of the responses.

Examples in this portfolio