# Cal. Code Civ. Proc. §§ 2016.010-2036.050 — Civil Discovery Act

- Citation: Cal. Code Civ. Proc., §§ 2016.010-2036.050
- Code: Code of Civil Procedure
- Subject: California Civil Discovery Act of 1986 (as amended)
- Source: https://leginfo.legislature.ca.gov/faces/codes_displayexpandedbranch.xhtml?tocCode=CCP
- Last verified: 2026-05-13

> Authored from canonical California statutory sources; verify
> against leginfo.legislature.ca.gov before relying.

## Overview

The California Civil Discovery Act of 1986 (recodified in 2004
into Title 4, Part 4 of the CCP — §§ 2016-2036) governs civil
discovery in California superior courts. Six methods are
authorized:

1. Depositions (§§ 2025-2028)
2. Interrogatories (§§ 2030.010-2030.310)
3. Inspection demands / RFPs (§§ 2031.010-2031.510)
4. Requests for admission / RFAs (§§ 2033.010-2033.420)
5. Physical and mental examinations (§§ 2032.010-2032.650)
6. Subpoenas duces tecum (§§ 2020.010-2020.510)

Key California-distinctive features:

- **35-special-interrogatory cap** (§ 2030.030(a))
- **45-day jurisdictional deadline** to file motion to compel
  further responses (§§ 2030.300(c), 2031.310(c), 2033.290(c))
- Separate-statement requirement for compel-further motions
  (CRC 3.1345)
- Discovery cutoff 30 days before trial; motions must be heard
  15 days before (§ 2024.020)

## Scope of discovery

### § 2017.010 — Scope

Unless otherwise limited by order of the court in accordance
with this title, any party may obtain discovery regarding any
matter, not privileged, that is relevant to the subject matter
involved in the pending action or to the determination of any
motion made in that action, if the matter either is itself
admissible in evidence or appears reasonably calculated to lead
to the discovery of admissible evidence. Discovery may relate
to the claim or defense of the party seeking discovery or of
any other party to the action.

The standard is intentionally broad: "relevant" + "reasonably
calculated to lead to admissible evidence."

## Cutoffs

### § 2024.020 — Trial-date cutoffs

**(a)** Except as otherwise provided in this chapter, any party
shall be entitled as a matter of right to complete discovery
proceedings on or before the **30th day**, and to have motions
concerning discovery heard on or before the **15th day**,
before the date initially set for the trial of the action.

**(b)** Except as provided in Section 2024.050, a continuance
or postponement of the trial date does not operate to reopen
discovery proceedings.

### § 2024.050 — Court's discretion to extend

Court may grant leave to complete discovery proceedings, or to
have a motion concerning discovery heard, closer to the initial
trial date, or to reopen discovery after a new trial date has
been set.

## Interrogatories

### § 2030.010 — Right to propound

Any party may propound written interrogatories to any other
party.

### § 2030.020 — Time to propound

The propounding party may serve interrogatories on the responding
party at any time after that party has been served or has
appeared in the action.

### § 2030.030 — NUMERICAL LIMITS (THE "RULE OF 35")

**(a)(1)** A party may propound to another party either or both
of the following:

**(A)** Thirty-five specially prepared interrogatories that are
relevant to the subject matter of the pending action.

**(B)** Any additional number of official form interrogatories,
as described in Chapter 17 (commencing with Section 2033.710),
that are relevant to the subject matter of the pending action.

**(b)** Except as provided in Section 2030.070, no party shall,
as a matter of right, propound to any other party more than 35
specially prepared interrogatories. If the initial set of
interrogatories does not exceed 35 specially prepared
interrogatories, the propounding party need not attach the
supporting declaration described in Section 2030.050.

### § 2030.040 — Declaration of necessity for additional interrogatories

**(a)** Subject to the right of the responding party to seek a
protective order under Section 2030.090, any party who attaches
a supporting declaration as described in Section 2030.050 may
propound a greater number of specially prepared interrogatories
to another party if this greater number is warranted because
of any of the following:

**(1)** The complexity or the quantity of the existing and
potential issues in the particular case.

**(2)** The financial burden on a party entailed in conducting
the discovery by oral deposition.

**(3)** The expedience of using this method of discovery to
provide to the responding party the opportunity to conduct
an inquiry, investigation, or search of files or records to
supply the information sought.

**(b)** If the responding party seeks a protective order on the
ground that the number of specially prepared interrogatories is
unwarranted, the propounding party shall have the burden of
justifying the number of these interrogatories.

### § 2030.050 — Required declaration of necessity

The declaration must state under penalty of perjury that:

(a) the requester has not propounded any other interrogatories
to the responding party,

(b) the additional interrogatories are appropriate per the
factors in § 2030.040,

(c) the requester has reviewed Judicial Council form
interrogatories and concluded that they are inadequate to
elicit the information sought.

### § 2030.060 — Form of interrogatories

Each interrogatory shall be numbered consecutively and contain
only one inquiry. No interrogatory may contain subparts or a
compound, conjunctive, or disjunctive question.

### § 2030.260 — Time to respond

**(a)** Within **30 days after service** of interrogatories,
the party to whom they are propounded shall serve the original
of the response on the propounding party, unless on motion of
the propounding party the court has shortened the time for
response, or unless on motion of the responding party the court
has extended the time for response.

**(b)** The 30-day period is extended by 5 calendar days for
in-state mail service (CCP § 1013(a)) or 2 court days for
e-service (CCP § 1010.6(a)(3)(B)).

### § 2030.300 — Motion to compel further responses

**(a)** On receipt of a response to interrogatories, the
propounding party may move for an order compelling a further
response if the propounding party deems that any of the
following apply:

(1) An answer to a particular interrogatory is evasive or
incomplete.

(2) An exercise of the option to produce documents under
Section 2030.230 is unwarranted or the required specification
of those documents is inadequate.

(3) An objection to an interrogatory is without merit or too
general.

**(b)(1)** A motion under subdivision (a) shall be accompanied
by a meet-and-confer declaration under Section 2016.040.

**(c) — 45-DAY JURISDICTIONAL DEADLINE**: Unless notice of this
motion is given **within 45 days of the service of the verified
response**, or any supplemental verified response, or on or
before any specific later date to which the propounding party
and the responding party have agreed in writing, the propounding
party waives any right to compel a further response to the
interrogatories.

**(d)(1)** The court shall impose a monetary sanction under
Chapter 7 (commencing with Section 2023.010) against any party,
person, or attorney who unsuccessfully makes or opposes a
motion to compel a further response to interrogatories, unless
it finds that the one subject to the sanction acted with
substantial justification or that other circumstances make the
imposition of the sanction unjust.

## Requests for Production / Inspection Demands

### § 2031.010 — Right to demand

Any party may obtain discovery within the scope delimited by
Chapter 2 (commencing with Section 2017.010), and subject to
the restrictions set forth in Chapter 5 (commencing with
Section 2019.010), by inspecting documents, tangible things,
land or other property, electronically stored information, or
testing or sampling.

### § 2031.020 — When may be served

The demanding party may serve an inspection demand on the
responding party at any time after that party has been served
or has appeared in the action.

### § 2031.260 — Time to respond

**(a)** Within **30 days after service** of an inspection
demand, the party to whom the demand is directed shall serve
the original of the response on the demanding party, and serve
a copy of the response on all other parties who have appeared
in the action.

### § 2031.310 — Motion to compel further responses

**(a)** On receipt of a response to a demand for inspection,
the demanding party may move for an order compelling further
response to the demand if the demanding party deems that any
of the following apply:

(1) A statement of compliance with the demand is incomplete.

(2) A representation of inability to comply is inadequate,
incomplete, or evasive.

(3) An objection in the response is without merit or too
general.

**(b)(1) — MEET-AND-CONFER**: A motion under subdivision (a)
shall be accompanied by a meet-and-confer declaration under
Section 2016.040.

**(b)(2)** A separate statement must be filed pursuant to
California Rules of Court, rule 3.1345.

**(c) — 45-DAY JURISDICTIONAL DEADLINE**: Unless notice of this
motion is given **within 45 days of the service of the verified
response**, or any supplemental verified response, or on or
before any specific later date to which the demanding party and
the responding party have agreed in writing, the demanding
party waives any right to compel a further response to the
demand.

**(h)** The court shall impose a monetary sanction under
Chapter 7 against any party, person, or attorney who
unsuccessfully makes or opposes a motion to compel further
response, unless substantial justification or other
circumstances make sanctions unjust.

### § 2031.320 — Failure to comply with order compelling response

If a party fails to obey an order compelling further response,
the court may make those orders that are just, including the
imposition of an issue sanction, an evidence sanction, or a
terminating sanction. The court may also impose a monetary
sanction.

## Requests for Admission

### § 2033.010 — Right to request

Any party may obtain discovery by requesting that another party
admit the genuineness of specified documents, the truth of
specified matters of fact, opinion relating to fact, or
application of law to fact.

### § 2033.030 — NUMERICAL LIMITS

**(a)** No party shall request, as a matter of right, that any
other party admit more than 35 matters that do not relate to
the genuineness of documents. If the initial set of admission
requests does not exceed 35 matters, no supporting declaration
is required.

**(b)** Any party who attaches a supporting declaration under
Section 2033.050 may request a greater number of admissions by
another party.

**(c)** Requests for admission directed to the genuineness of
documents are not subject to the 35-matter cap.

### § 2033.250 — Time to respond

**(a)** Within **30 days after service** of requests for
admission, the party to whom the requests are directed shall
serve the original of the response on the requesting party, and
serve a copy of the response on all other parties who have
appeared in the action.

### § 2033.280 — Effect of failure to respond — DEEMED ADMITTED

**(a)** If a party to whom requests for admission are directed
fails to serve a timely response, the following rules apply:

(1) The party to whom the requests for admission are directed
waives any objection to the requests, including one based on
privilege or on the protection for work product under Chapter
4 (commencing with Section 2018.010).

(2) The requesting party may move for an order that the
genuineness of any documents and the truth of any matters
specified in the requests be deemed admitted, as well as for a
monetary sanction.

**(c)** The court shall make this order, unless it finds that
the party to whom the requests for admission have been directed
has served, before the hearing on the motion, a proposed
response to the requests for admission that is in substantial
compliance with Section 2033.220.

### § 2033.290 — Motion to compel further responses

Parallel to §§ 2030.300, 2031.310 — 45-day jurisdictional
deadline, separate-statement requirement, sanctions.

## Depositions

### § 2025.010 — Right to depose

Any party may obtain discovery by taking in California the oral
deposition of any person, including any party to the action.

### § 2025.220 — Notice of deposition

A party desiring to take an oral deposition shall give notice
in writing.

### § 2025.270 — Time of notice

**(a)** An oral deposition shall be scheduled for a date at
least **10 days after service** of the deposition notice.

Service of papers extensions per § 1013 / § 1010.6 apply.

### § 2025.450 — Motion to compel attendance / production

If, after service of a deposition notice, a party fails to
appear or refuses to be sworn or to answer a question, the
party giving the notice may move for an order compelling
attendance, testimony, and production.

## Sanctions

### § 2023.030 — Sanctions

To the extent authorized by the chapter governing any particular
discovery method or any other provision of this title, the court,
after notice to any affected party, person, or attorney, and
after opportunity for hearing, may impose the following appropriate
sanctions against anyone engaging in conduct that is a misuse
of the discovery process:

**(a)** Monetary sanction (the court may impose a monetary
sanction ordering that one engaging in the misuse of the
discovery process, or any attorney advising that conduct, or
both pay the reasonable expenses, including attorney's fees,
incurred by anyone as a result of that conduct).

**(b)** Issue sanction (one or more designated facts shall be
taken as established in the action).

**(c)** Evidence sanction (party engaging in the misuse shall
not be permitted to support or oppose designated claims or
defenses).

**(d)** Terminating sanction (the most severe — striking out
pleadings, rendering judgment by default, dismissing the
action).

**(e)** Contempt sanction.

### Mandatory sanctions

Sanctions are mandatory under §§ 2030.300(d), 2031.310(h),
2033.290(d) when a party unsuccessfully makes or opposes a
motion to compel a further response, **unless the court finds
substantial justification or other circumstances making
sanctions unjust**. The default is sanctions; the burden is on
the party opposing sanctions to show substantial justification.

## Meet-and-Confer Requirements

### § 2016.040 — Meet-and-confer declaration

A meet-and-confer declaration in support of a motion shall
state facts showing a reasonable and good faith attempt at an
informal resolution of each issue presented by the motion.

The declaration must:

1. Identify the issues attempted to be resolved
2. Describe the meet-and-confer efforts (date, format, attendees)
3. State whether agreement was reached
4. State whether the meet-and-confer failed in good faith

## Cross-references

- `../court-rules/CRC-Title-3-Civil-Rules.md` — CRC 3.1345
  (separate-statement requirement)
- `CCP-Motions-1005-to-1020.md` — motion notice / opposition /
  reply timing for compel motions
- `../../../ca-discovery/SKILL.md` — workflow that uses these
  statutes
- `../../../ca-discovery/references/meet-and-confer.md` —
  practitioner-facing M&C guidance
- `../../../../scripts/case-calendar.py` — named rules
  `rfp-response`, `rog-response`, `rfa-response`,
  `motion-compel-further` (the 45-day deadline)