When it's used
Within 30 days of service of Special Interrogatories, with objections stated in the response itself.
Definition
SROG responses are verified, written answers—or properly stated objections—to the opposing party’s specially drafted interrogatories, governed by California CCP §2030.210. Because SROGs are custom-crafted questions targeting the specific vulnerabilities of a party’s case, the paralegal must analyze each question carefully: drafting a complete, accurate answer where the question is proper, and preparing well-grounded objections on grounds such as attorney-client privilege, work-product, overbreadth, or undue burden where the question overreaches. Objections must be specific; a boilerplate or general objection risks being overruled outright on a motion to compel. The paralegal coordinates the client interview, marshals the supporting documents, and ensures the final response set is internally consistent with all other discovery already provided.