In general, Special Interrogatories are questions asked to the other side in written form. The questions should be straightforward and concise. The law governing Special Interrogatories (in CA) is outlined in the Code of Civil Procedure. Below, I have tried to describe some helpful tips re the law and the usage of the Special Interrogatories in the Family Law realm. First, Special Interrogatories, are normally limited to 35 inquiries. This limit may be increased by way of a declaration of necessity. Said declaration will generally need to describe the need for the additional demands and its appropriateness of allowing the proponent to exceed 35 inquiries i.e. cheaper than taking a deposition. Second, the demand for Special Interrogatories may be useful when trying to assess the legitimacy of a FC Section 2640 claim for reimbursement. For instance, your interrogatory may request that the opposing party identify all documents supporting his or her claim for reimbursement. Once this is done you may then request production of the identified documents. Said demand may be made with a Notice for Production of Documents. I usually propound the interrogatories and the demand together. This saves time and money. Third, forcing an individual to identify all items in this manner usually prevents "gotcha litigation" or sand bagging by other side. Lastly, when all the cards are on the table, I normally see good faith settlement talks commencing from both sides. Said settlement would either recognize the reimbursements (assuming their proven up) or disregard them. This method of discovery usually limits the he said she said and helps get to the finish line.
