California Civil Jury Instructions (CACI) (2017)

209. Use of Interrogatories of a Party

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209.Use of Interrogatories of a Party
Before trial, each party has the right to ask the other parties to answer
written questions. These questions are called interrogatories. The
answers are also in writing and are given under oath. You must
consider the questions and answers that were read to you the same as if
the questions and answers had been given in court.
New September 2003
Sources and Authority
• Use of Interrogatories at Trial. Code of Civil Procedure section 2030.410.
• “Admissions contained in depositions and interrogatories are admissible in
evidence to establish any material fact.” (Leasman v. Beech Aircraft Corp.
(1975) 48 Cal.App.3d 376, 380 [121 Cal.Rptr. 768].)
Secondary Sources
3 Witkin, California Evidence (4th ed. 2000) Presentation at Trial, § 163
7 Witkin, California Procedure (4th ed. 1997) Trial, § 304
1A California Trial Guide, Unit 20, Procedural Rules for Presentation of Evidence,
§ 20.50 (Matthew Bender)
16 California Forms of Pleading and Practice, Ch. 194, Discovery: Interrogatories,
§ 194.26 (Matthew Bender)
Matthew Bender Practice Guide: California Civil Discovery, Ch. 9, Interrogatories,