Exceeding numeric restriction on interrogatoties
I am a plaintiff in pro per. I am using the interrogatories form DISC-001 and checking all the relevant questions that I want the defendant to answer. The total number of questions checked came to 20. By studing Model Interrogatories by Kevin R. Culhane, I am propounding additional 50 questions to the defendant. Since my total questions exceed the number of specially prepared interrogatories permitted by Section 2030.030 of the Code of Civil Procedure, I prepared a declration for additional discovery. Here are my questions:
1) Can I put sequential numbers on 20 checked questions on DISC-001?
2) What should be the starting number on the set of additional interrogatories?
3) Can I use declration for additional discovery for RFA and request for production of documents?
I appreciate your advice.