How to Write and Send Interrogatories Without a Lawyer (California, Texas, and Illinois)

Savage Lex Team · 2026-08-25

How to Write and Send Interrogatories Without a Lawyer (California, Texas, and Illinois)

You're in a lawsuit. You need information from the other side — maybe they're hiding something, maybe you just need to lock down their story before trial. Interrogatories are written questions the other party has to answer under oath. They're cheap, they're effective, and you can send them yourself.

Here's how they work in California, Texas, and Illinois: the limits, the deadlines, the forms, and the mistakes that get your questions tossed.

What Are Interrogatories, Exactly?

Interrogatories are written questions you send to another party in your lawsuit. They answer in writing, under oath, within a set number of days. Their answers can be used as evidence at trial. If they lie, they're lying under oath.

This is different from a deposition. No court reporter. No scheduling headaches. The other side gets time to research their answer instead of fumbling on the spot. That's a double-edged sword: they can craft careful responses, but they can't later claim they didn't understand the question.

You can ask about facts, identify witnesses, describe injuries, list documents, and pin down legal theories. What you can't do: use interrogatories to make the other side do your homework, or ask questions that are irrelevant, harassing, or absurdly broad.

How Many Can You Send?

Every state caps the number. Go over without court permission and the other side can ignore your extras.

|-------|-------|------|-------|

California gives you the most room. You get 35 you write yourself, plus unlimited official Judicial Council form interrogatories — those cover common ground like witness ID, insurance, and damages. If 35 isn't enough, you can ask the court for more with a declaration explaining why (CCP § 2030.040–2030.050).

Texas is tighter. Most cases fall under Level 2 discovery: 25 interrogatories. Expedited actions or cases under $100,000 get 15 (Level 1). The trap here is subparts. Write "State the date, time, location, and weather conditions when the accident happened" and a court could count that as four questions, not one.

Illinois gives you 30, subparts included. Supreme Court-approved form interrogatories count as one each regardless of subparts — another good reason to use the forms when they fit.

Deadlines

| State | Response Deadline | Rule |

|-------|------------------|------|

| California | 30 days | CCP § 2030.260(a) |

| California (unlawful detainer) | 5 days | CCP § 2030.260(b) |

| Texas | 30 days | TRCP 197.2(a) |

| Texas (family code defendant, served before answer due) | 50 days | TRCP 197.2(a) |

| Illinois | 28 days | Rule 213(d) |

If the deadline passes and you've got nothing, you can file a motion to compel. California usually requires a meet-and-confer attempt first (CCP § 2030.300). Texas lets you seek sanctions if the other side is stalling without good cause (TRCP 215). In Illinois, the court hears objections on prompt motion from the party who sent the interrogatories (Rule 213(d)).

How to Write Interrogatories That Actually Work

Bad interrogatories waste your limited count and collect objections. Here's how to write ones that get real answers.

Be specific. "Describe everything that happened on March 15" is a gift to the other side's objection. "State the exact time you arrived at 123 Main St. on March 15, 2026, and identify every person present when you arrived" — that's specific enough to force a real answer.

One thing per question. Don't stack five questions into one. In Texas and Illinois, subparts count against your limit. Even in California, compound questions invite partial objections.

Ask for facts, not legal conclusions. "State the basis for your negligence claim" works. "Explain why you were negligent" asks for a legal conclusion they don't have to give.

Identify documents and witnesses. Some of the best interrogatories force the other side to disclose people and paperwork early. "Identify every person who witnessed the collision on March 15, 2026, and state their current address and phone number" — that's the kind of question that wins cases.

Use form interrogatories. In California, Judicial Council form interrogatories don't count against your 35. In Illinois, approved forms count as one each regardless of subparts. Check your court's website.

How to Serve Them

You don't file interrogatories with the court. You serve them on the other party — deliver them according to your state's service rules.

California: Mail, express mail, overnight delivery, or electronic service if the other side agreed to it. Include a proof of service (Judicial Council form POS-030 works). Serve copies on all other parties too (CCP § 2030.060).

Texas: Any method allowed under TRCP 21a — certified mail, commercial delivery, or electronic service if agreed. Here's the thing: you have to sign them. No signature, no obligation to answer (TRCP 197.1).

Illinois: Serve on the other party with proof of service on everyone else entitled to notice. Answers must be sworn — the other side signs under oath (Rule 213(d)).

What You Get Back

Their answers will come in one of three flavors:

A real answer. They respond with the information you asked for. Great.
An objection. They claim the question is irrelevant, overly broad, privileged, or otherwise improper. They don't answer. You have to decide whether to fight it.
A reference to records. In Texas and California, the other side can answer by pointing you to business records or public records where the answer lives — as long as finding it there is about as easy for you as for them (TRCP 197.2(c); CCP § 2030.230).

No answer at all? Evasive answers? File a motion to compel. The court can order them to respond and may make them pay your costs for bringing the motion.

Mistakes That Sink Pro Se Interrogatories

Sending too many. You have a limited supply. Don't burn 10 of your 25 on questions you already know the answer to.

Being too vague. "Tell me everything about the accident" gets an objection every time. Narrow it down.

Missing the service deadline. In Texas, interrogatories must be served no later than 30 days before discovery closes (TRCP 197.1). Don't wait.

Not counting subparts. In Texas and Illinois, they count. Write accordingly.

Forgetting to verify. In California and Texas, answers must be signed under oath. Unverified answers aren't proper responses. Point that out.

Not following up. If they don't answer, do something. A motion to compel tells the court you're serious.

What Interrogatories Can't Do

They're powerful, but they have edges:

Only parties in the lawsuit. For witnesses or third parties, you need a subpoena or a request for production.
They don't force document production — that's a separate tool.
They can't require the other side to do extensive research or compile data from multiple sources if the burden outweighs the value.

Quick Reference

|---|-----------|-------|----------|

| Answers verified? | Yes | Yes | Yes (sworn) |

| Subparts count? | No explicit rule | Yes | Yes |

What to Do Next

Find your discovery deadlines. Check the scheduling order in your case — it tells you when discovery opens and closes.
Draft your interrogatories. Start with what matters most. Use form interrogatories where they apply.
Count carefully. Stay within your state's limit. In Texas and Illinois, count every subpart.
Serve them right. Follow your state's service rules. Keep proof of service.
Calendar the response deadline. If they miss it, you have options — but only if you act.

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General legal information, not legal advice. Rules vary by jurisdiction and can change. Consult an attorney for your specific situation.

Sources

California Code of Civil Procedure § 2030.030 — leginfo.legislature.ca.gov
California Code of Civil Procedure § 2030.260 — leginfo.legislature.ca.gov
California Courts Self Help: Form Interrogatories — selfhelp.courts.ca.gov
Texas Rules of Civil Procedure, Rule 190 (Discovery Limitations) — texaslegalrules.com
Texas Rules of Civil Procedure, Rule 197 (Interrogatories to Parties) — state-rules.com
TexasLawHelp: Interrogatories — texaslawhelp.org
Illinois Supreme Court Rule 213 (Written Interrogatories to Parties) — illinoiscourts.gov
Illinois Rule 213 — courtrules.net