When it's used
During the written discovery phase to probe case-specific facts not covered by the Judicial Council form.
Definition
Special Interrogatories are attorney-drafted written questions tailored to the unique facts of a particular case, used to compel an opposing party to provide detailed narrative responses under oath. California CCP §2030.030(a)(1) limits each party to 35 specially prepared interrogatories without a court order or declaration of necessity, so the paralegal must draft questions that are precise, strategically prioritized, and free of compound or ambiguous phrasing that would invite objection. The paralegal works from the attorney’s outline to craft clear, non-compound questions, then prepares the cover page, definitions section, and proof of service before the attorney reviews and approves. Responses to SROGs often surface the factual admissions and contentions that shape deposition strategy and motion practice.