# Specially Prepared Interrogatories — California Debt-Buyer Cases

California permits **specially prepared interrogatories** in civil
discovery under CCP § 2030.010 et seq. Unlike Oregon (which has
no written interrogatories in standard civil practice), California
allows interrogatories as a matter of right.

> **NOT LEGAL ADVICE.** Verify current CCP provisions.

## California interrogatory rules — quick reference

| Rule | Citation | Content |
|------|----------|---------|
| Right to propound | CCP § 2030.010(a) | Any party may serve interrogatories |
| Limit (specially prepared) | CCP § 2030.030(a)(1) | 35 specials without declaration |
| Over 35 requires declaration | CCP § 2030.040 | Declaration stating necessity |
| Response deadline | CCP § 2030.260 | 30 days after service |
| Motion to compel further | CCP § 2030.300(b) | 45 days from service of responses |
| Form interrogatories | Cal. Rules of Court | DISC-001 (General); DISC-002 (Economic Damages) |

**Strategic note**: California's 35-special-interrogatory limit
is far more generous than federal's 25-interrogatory limit
(FRCP 33). Design the bank to use all 35 effectively.
In addition, serve **Form Interrogatories DISC-001** (General)
and **DISC-002** (Economic Damages) — these do not count toward
the 35-special limit.

## DEFINITIONS (to include in interrogatory preamble)

```
For purposes of these Interrogatories:

"ACCOUNT" means the credit-card account number ending in
[last 4 digits], allegedly opened by Defendant [Name] with
[Original Creditor], as referenced in Plaintiff's Complaint.

"PLAINTIFF" means [Plaintiff entity name], its officers,
employees, agents, servicers, and any affiliate.

"ORIGINAL CREDITOR" means [Bank of America / Capital One /
etc.], and any subsidiary, affiliate, or predecessor.

"DOCUMENT" has the meaning of Cal. Evid. Code § 250.

"CHAIN OF TITLE" means the transfer of the ACCOUNT from
the ORIGINAL CREDITOR through all intermediate debt buyers
to PLAINTIFF.

"COMMUNICATION" means any exchange of information, including
oral, written, or electronic.
```

## SPECIALLY PREPARED INTERROGATORIES (up to 35)

### Set A: Corporate identity and CDCLA licensing (1–5)

**INTERROGATORY NO. 1**:

> State the full legal name, state of formation, principal
> place of business, and California address (if any) of
> Plaintiff [LVNV Funding, LLC].

**INTERROGATORY NO. 2**:

> State whether Plaintiff holds a valid, active license
> from the California Department of Financial Protection and
> Innovation (DFPI) under Cal. Fin. Code, § 100002 as of
> the date this action was filed. If yes, state the license
> number, issuance date, and current status. If no, explain
> why Plaintiff contends it is exempt from the licensing
> requirement.

**INTERROGATORY NO. 3**:

> Identify all entities that are related to Plaintiff
> (parent, subsidiary, affiliate) that have collected or
> attempted to collect the ACCOUNT on Plaintiff's behalf,
> including the name of each entity, its role, and the
> period during which it acted.

**INTERROGATORY NO. 4**:

> Identify all third-party servicers, collection agencies,
> or agents (other than attorneys of record) that collected
> or attempted to collect the ACCOUNT on behalf of Plaintiff
> or any predecessor in interest, including the name of each,
> the period of engagement, and whether each holds a DFPI
> license.

**INTERROGATORY NO. 5**:

> Describe the nature of Plaintiff's business, including the
> approximate number of consumer debt accounts that Plaintiff
> owned or serviced in California during the past 3 years,
> and the total estimated face value of those accounts.

### Set B: Account opening and original creditor (6–10)

**INTERROGATORY NO. 6**:

> State the date the ACCOUNT was opened with the Original
> Creditor, the initial credit limit, and whether the
> account was opened in person, by mail, or electronically.

**INTERROGATORY NO. 7**:

> State the name of each version of the cardholder agreement
> applicable to the ACCOUNT during its life, and state
> whether Plaintiff possesses a copy of each version.

**INTERROGATORY NO. 8**:

> State the date of the first missed payment on the ACCOUNT,
> the date of the last payment by Defendant on the ACCOUNT,
> and the payment amount.

**INTERROGATORY NO. 9**:

> State the date the Original Creditor charged off the
> ACCOUNT, the balance at charge-off (broken down by
> principal, accrued interest, fees, and other charges),
> and how the charge-off balance was calculated.

**INTERROGATORY NO. 10**:

> State whether the Original Creditor reported the charge-
> off of the ACCOUNT to any consumer reporting agency, and
> if so, the date and content of the report.

### Set C: Chain of title (11–17)

**INTERROGATORY NO. 11**:

> Identify each entity in the complete chain of title of
> the ACCOUNT from the Original Creditor to Plaintiff,
> including (a) the name of each buyer and seller;
> (b) the date of each transfer; (c) the consideration
> paid or method of valuation; and (d) the document
> (Bill of Sale, Assignment, or other) evidencing each
> transfer.

**INTERROGATORY NO. 12**:

> State whether the assignment of the ACCOUNT to Plaintiff
> included the original cardholder agreement between
> Defendant and the Original Creditor. If yes, identify
> the document by title and date. If no, state why not and
> whether Plaintiff has a right to obtain it.

**INTERROGATORY NO. 13**:

> Identify all persons with personal knowledge of the
> chain of title of the ACCOUNT from the Original Creditor
> to Plaintiff, including each person's full name, current
> employer, position, and contact information.

**INTERROGATORY NO. 14**:

> Identify any custodian of records from the Original
> Creditor (or any intermediate debt buyer) who has
> provided, or is expected to provide, testimony or a
> declaration regarding the ACCOUNT in this case.

**INTERROGATORY NO. 15**:

> Describe all documents Plaintiff received from the seller
> when Plaintiff purchased the ACCOUNT, including each
> document's title, date, and the type of information it
> contains. Identify each such document in Plaintiff's
> possession, custody, or control.

**INTERROGATORY NO. 16**:

> Describe Plaintiff's process for verifying that the
> accounts it purchases from debt sellers are accurately
> identified as belonging to the named debtors, including
> the steps taken to verify the ACCOUNT belongs to
> Defendant.

**INTERROGATORY NO. 17**:

> State whether the bulk sale agreement under which
> Plaintiff acquired the ACCOUNT contained any
> representations or warranties from the seller regarding
> the accuracy of the account data, and if so, describe
> those representations or warranties.

### Set D: Balance and amount sought (18–21)

**INTERROGATORY NO. 18**:

> State the itemized breakdown of the amount claimed in the
> Complaint, including principal, interest (with rate and
> accrual period), fees, and other charges. Identify the
> contractual or legal basis for each component.

**INTERROGATORY NO. 19**:

> State whether any interest accrued on the ACCOUNT after
> the date of charge-off. If yes, state the rate, the
> contractual authority for the post-charge-off interest,
> and the total amount of post-charge-off interest claimed.

**INTERROGATORY NO. 20**:

> State whether any fees were added to the ACCOUNT after
> the date of charge-off. If yes, identify each fee,
> the amount, the date added, and the contractual or
> statutory authority for the fee.

**INTERROGATORY NO. 21**:

> State the total amount Plaintiff paid to acquire the
> ACCOUNT (or Plaintiff's best estimate of the per-account
> cost, given that accounts are typically sold in pools).

### Set E: Pre-suit notice and FDBPA compliance (22–25)

**INTERROGATORY NO. 22**:

> State whether Plaintiff sent Defendant a written pre-suit
> notice as required by Cal. Civ. Code, § 1788.60. If yes,
> state the date sent, the method of delivery, the address
> to which it was sent, and identify the document. If no,
> state Plaintiff's basis for the contention that notice
> was not required.

**INTERROGATORY NO. 23**:

> Describe all documentation Plaintiff had in its possession
> before filing this action as required by Cal. Civ. Code,
> § 1788.52, including documentation of (a) the chain of
> title; (b) the account balance; and (c) the account
> identification information.

**INTERROGATORY NO. 24**:

> Identify all documents Plaintiff intends to offer as
> evidence at trial in this action, including the document's
> title, date, author, and the basis for authentication
> under Cal. Evid. Code § 1271, § 1400, and § 1561.

**INTERROGATORY NO. 25**:

> Identify all witnesses Plaintiff intends to call at
> trial, including their full name, employer, position,
> and a brief description of the subject of their expected
> testimony.

### Set F: Validation notice and dispute handling (26–28)

**INTERROGATORY NO. 26**:

> State whether Plaintiff (or any agent) sent Defendant a
> validation notice as required by 15 U.S.C. § 1692g(a)
> and 12 CFR § 1006.34. If yes, state the date, method
> of delivery, and identify the document. If no, state
> Plaintiff's basis for contending no validation notice
> was required.

**INTERROGATORY NO. 27**:

> State whether Defendant disputed the ACCOUNT with
> Plaintiff (or any agent of Plaintiff) under 15 U.S.C.
> § 1692g. If yes, state the date, method, and substance
> of the dispute, and describe the verification Plaintiff
> provided in response.

**INTERROGATORY NO. 28**:

> State whether Plaintiff has any record of Defendant
> requesting, in writing, that Plaintiff cease collection
> communications. If yes, state the date of the request
> and describe any collection communications sent by
> Plaintiff after the date of the request.

### Set G: Statute of limitations (29–31)

**INTERROGATORY NO. 29**:

> State Plaintiff's basis for contending that this action
> is timely under CCP § 337 (4-year limitations period for
> written contracts), including the specific date that
> Plaintiff contends accrued as the limitations start date
> and any event that Plaintiff contends restarted the
> limitations period.

**INTERROGATORY NO. 30**:

> Identify all written documents signed by Defendant that
> Plaintiff contends constitute a written acknowledgment
> of the ACCOUNT under CCP § 360, sufficient to restart
> the statute of limitations. Include the date of each
> document, its content, and where Plaintiff obtained it.

**INTERROGATORY NO. 31**:

> State the date(s) of any payment by Defendant on the
> ACCOUNT that Plaintiff contends restarted the statute
> of limitations under CCP § 360. Include the amount,
> the date received, and how the payment was received.

### Set H: Communication conduct (32–35)

**INTERROGATORY NO. 32**:

> Identify all telephone calls made to Defendant (or to
> any number associated with Defendant) by Plaintiff or
> any agent of Plaintiff regarding the ACCOUNT, including
> the date, time, duration, calling number, and called
> number for each call.

**INTERROGATORY NO. 33**:

> State whether Plaintiff (or any agent) telephoned
> Defendant more than 7 times in any 7-consecutive-calendar-
> day period. If yes, identify each such period.

**INTERROGATORY NO. 34**:

> Identify all written communications sent to Defendant
> regarding the ACCOUNT, including collection letters,
> emails, text messages, and any other written contact,
> with the date and method of delivery for each.

**INTERROGATORY NO. 35**:

> Describe all collection efforts made on the ACCOUNT,
> in chronological order, including all lawsuits filed,
> judgments obtained, garnishment actions, and settlement
> discussions, with dates for each.

## Over-35 declaration (CCP § 2030.040)

If the case requires more than 35 specially prepared
interrogatories, file a supporting declaration under
CCP § 2030.040 stating:

- The complexity of the case
- The necessity of additional interrogatories
- That the limit will not be used for harassment or burden

## Form interrogatories

Serve DISC-001 (General) and DISC-002 (Economic Damages
Interrogatories) alongside the specially prepared bank.
Form interrogatories are not subject to the 35-special limit.

Key DISC-001 interrogatories for debt-defense:
- 1.0 (Identity of responding party)
- 2.0 (Corporate structure and nature of business)
- 11.0 (Claims for damages)
- 12.0 (Investigation of claims)
- 14.0 (Admitted facts)
- 15.0 (Contentions and facts)
- 16.0 (Documents)
- 17.0 (Parties)

## Cross-references

- `ca-consumer-debt` SKILL — main bundle
- `ca-discovery` SKILL — California discovery framework
- `references/rfp-debt-buyer.md` — companion RFPs
- `references/rfa-debt-buyer.md` — companion RFAs
- `references/meet-and-confer-debt-buyer.md` — M&C templates
  for interrogatory disputes