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Assignment Two
Representing Defendant, each student shall draft fifteen (15) Special Interrogatories to Plaintiff. You may not use boilerplate formbook questions, Judicial Council forms, or questions with sub-parts. Your Interrogatories are to be typed on pleading paper in the proper format as required by Code of Civil Procedure section 2030.060—use the assignment shell provided. As acting defense attorneys, your goal is to prove the factual elements underlying your affirmative defenses as alleged in your answer, and secondarily to disprove Plaintiff’s story by suggesting a different version of the facts is actually what happened. Part two of this assignment is to draft ten (10) Requests for Admission to Plaintiff with your Interrogatories. Consult Code of Civil Procedure (Section 2033.060) for the proper format—use the assignment shell provided. Prepare each set (Special Interrogatories & Requests for Admission) by using the assignment shells. You will turn them in via the Canvas assignment tool set up for you. Remember, the main difference in the two discovery devices that interrogatories are used to discover unknown facts and Requests for Admissions are used to affirm known facts, or to affirm the genuineness of a document. Your Interrogatories and Requests for Admission are two separate discovery initiatives. Each must stand on its own with a Proof of Service. You will receive one grade for this assignment—a combination of Interrogatories and Requests for Admission.
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