Requirements of the Form of Interrogatories
It is critical that special interrogatories be drafted in accordance with this section, and that you make them as simple and clear as possible. It is too expensive to fight over the form of the questions through "meet and confers" and "motions to compel" and compound, jumbled, ambiguous questions ultimately will become a huge waste of time.
CALIFORNIA CODE OF CIVIL PROCEDURE
C.C.P. Section 2030.060
(a) A party propounding interrogatories shall number each set of interrogatories consecutively.
(b) In the first paragraph immediately below the title of the case, there shall appear the identity of the propounding party, the set number, and the identity of the responding party.
(c) Each interrogatory in a set shall be separately set forth and identified by number or letter.
(d) Each interrogatory shall be full and complete in and of itself. No preface or instruction shall be included with a set of interrogatories unless it has been approved under Chapter 17 (commencing with Section 2033.710).
(e) Any term specially defined in a set of interrogatories shall be typed with all letters capitalized wherever that term appears.
(f) No specially prepared interrogatory shall contain subparts, or a compound, conjunctive, or disjunctive question.
(g) An interrogatory may not be made a continuing one so as to impose on the party responding to it a duty to supplement an answer to it that was initially correct and complete with later acquired information.