I, __________ [declarant name], declare:
1. I am __________ [a party to this __________ (action
proceeding) appearing in propria persona or the attorney of
record for __________ (name of party), a party to this
__________ (action or proceeding)].
2. I am propounding the attached set of interrogatories,
Set Number __________[s, to __________ [responding party], the
__________ [plaintiff or defendant] in the above cause of
3. Propounding Set __________ to __________ [responding
party] will cause the total number of specially prepared
interrogatories submitted to __________ [him or her] to exceed
the number of specially prepared interrogatories permitted by
section 2030(c)(1) of the Code of Civil Procedure.
4. To date, I have propounded to __________ [responding
party] a total of _____ interrogatories __________ [if
applicable, add the following: of which _____ were specially
5. Set Number _____ contains a total of _____ specially
6. I am familiar with the issues presented by this case,
and the previous discovery conducted by all parties in the
7. I have personally examined each of the
in Set Number _____.
8. The additional number of specially prepared
interrogatories in Set Number _____ is warranted under section
2030(c)(2) of the Code of Civil Procedure __________ [state
statutory factors relied on, and reasons why each factor
relied on is applicable to instant lawsuit].
9. __________ [Propounding party] has not propounded the
interrogatories contained in Set _____ for an improper
purpose, such as to harass __________ [responding party], or
_____ [his or her] attorney, or to cause unnecessary delay, or
to cause a needless increase in the cost of litigation.
I declare under penalty of perjury under the laws of the
State of California that the foregoing is true and correct,
and that this declaration was executed on __________ [date].