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California Unlawful Detainer Interrogatories

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FORM INTERROGATORIES—UNLAWFUL DETAINER

ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):

TEL. NO.:

UNLAWFUL DETAINER ASSISTANT

(Check one box): An unlawful detainer assistant

did

did not for compensation give advice or assistance with this form. (If one did, state the following):

ASSISTANT'S NAME:

ADDRESS:

ATTORNEY FOR (Name):

COUNTY OF REGISTRATION:

REGISTRATION NO.:

EXPIRES (DATE):

SUPERIOR COURT OF CALIFORNIA, COUNTY OF:

SHORT TITLE:

FORM INTERROGATORIES—UNLAWFUL DETAINER

Asking Party:

Answering Party:

Set No.:

CASE NUMBER:

Sec. 1. Instructions to All Parties

(a) These are general instructions. For time limitations, requirements for service on other parties, and other details, see Code of Civil Procedure sections 2030.010-2030.410 and the cases construing those sections.

(b) These interrogatories do not change existing law relating to interrogatories nor do they affect an answering party's right to assert any privilege or objection.

(c) Each answer must be as complete and straightforward as the information reasonably available to you permits. If an interrogatory cannot be answered completely, answer it to the extent possible.

(d) If you do not have enough personal knowledge to fully answer an interrogatory, say so, but make a reasonable and good faith effort to get the information by asking other persons or organizations, unless the information is equally available to the asking party.

(e) Whenever an interrogatory may be answered by referring to a document, the document may be attached as an exhibit to the response and referred to in the response. If the document has more than one page, refer to the page and section where the answer to the interrogatory can be found.

(f) Whenever an address and telephone number for the same person are requested in more than one interrogatory, you are required to furnish them in answering only the first interrogatory asking for that information.

Sec. 3. Instructions to the Answering Party

(a) An answer or other appropriate response must be given to each interrogatory checked by the asking party. Failure to respond to these interrogatories properly can be punished by sanctions, including contempt proceedings, fine, attorneys fees, and the loss of your case.

Verification

DATE:

Signature

Sec. 4. Definitions

Words in BOLDFACE CAPITALS in these interrogatories are defined as follows:

(a) PERSON includes a natural person, firm, association, organization, partnership, business, trust, corporation, or public entity.

(b) PLAINTIFF includes any PERSON who seeks recovery of the RENTAL UNIT whether acting as an individual or on someone else's behalf and includes all such PERSONS if more than one.

Sec. 5. Interrogatories

The following interrogatories have been approved by the Judicial Council under section 2033.710 of the Code of Civil Procedure for use in unlawful detainer proceedings:

CONTENTS

70.0 General

71.0 Notice

72.0 Service

73.0 Malicious Holding Over

74.0 Rent Control and Eviction Control

75.0 Breach of Warranty to Provide Habitable Premises

76.0 Waiver, Change, Withdrawal, or Cancellation of Notice to Quit

77.0 Retaliation and Arbitrary Discrimination

78.0 Nonperformance of the Rental Agreement by Landlord

79.0 Offer of Rent by Defendant

80.0 Deduction from Rent for Necessary Repairs

81.0 Fair Market Rental Value

70.0 General

[Either party may ask any applicable question in this section.]

70.1 State the name, address, telephone number, and relationship to you of each person who prepared or assisted in the preparation of the responses to these interrogatories.

70.2 Is PLAINTIFF an owner of the RENTAL UNIT? If so, state the nature and percentage of ownership interest and the date first acquired.

70.3 Does PLAINTIFF share ownership or lack ownership? If so, state the name, address, and nature and percentage of ownership interest of each owner.

70.4 Does PLAINTIFF claim the right to possession other than as an owner of the RENTAL UNIT? If so, state the basis of the claim.

70.5 Has PLAINTIFF'S interest in the RENTAL UNIT changed since acquisition? If so, state the nature and dates of each change.

70.6 Are there other rental units on the PROPERTY? If so, state how many.

70.7 During the 12 months before this proceeding was filed, did PLAINTIFF possess a permit or certificate of occupancy for the RENTAL UNIT?

70.8 Has a last month's rent, security deposit, cleaning fee, rental agency fee, credit check fee, key deposit, or any other deposit been paid on the RENTAL UNIT?

70.9 State the date defendant first took possession of the RENTAL UNIT.

70.10 State the date and all the terms of any rental agreement between defendant and the PERSON who rented to defendant.

71.0 Notice

[If a defense is based on allegations that the 3-day notice or 30-day NOTICE TO QUIT is defective in form or content, then either party may ask any applicable question in this section.]

71.1 Was the NOTICE TO QUIT on which PLAINTIFF bases this proceeding attached to the complaint? If not, state the contents of this notice.

71.2 State all reasons that the NOTICE TO QUIT was served and for each reason.

71.3 List all rent payments and rent credits made or claimed by or on behalf of defendant beginning 12 months before the NOTICE TO QUIT was served.

71.4 Did defendant ever fail to pay the rent on time? If so, for each late payment state.

71.5 Since the beginning of defendant's tenancy, has PLAINTIFF ever raised the rent? If so, for each rent increase state.

71.6 During the 12 months before the NOTICE TO QUIT was served was there a period during which there was no permit or certificate of occupancy for the RENTAL UNIT?

71.7 Has any PERSON ever reported any nuisance or disturbance at or destruction of the RENTAL UNIT or PROPERTY caused by defendant or other occupant of the RENTAL UNIT or their guests?

72.0 Service

[If a defense is based on allegations that the NOTICE TO QUIT was defectively served, then either party may ask any applicable question in this section.]

72.1 Does defendant contend that the NOTICE TO QUIT was defectively served?

Yes

72.2 Does PLAINTIFF contend that the NOTICE TO QUIT referred to in the complaint was served? If so, state the kind of notice, date and time, manner, server, and conversation/document details.

72.3 Did any person receive the NOTICE TO QUIT referred to in the complaint? If so, state all delivery details.

73.0 Malicious Holding Over

[If a defendant denies allegations that defendant's continued possession is malicious, then either party may ask any applicable question in this section.]

73.1 If any rent called for by the rental agreement is unpaid, state the reasons and the facts upon which the reasons are based.

73.2 Has defendant made attempts to secure other premises since the service of the NOTICE TO QUIT or since the service of the summons and complaint?

73.3 State the facts upon which PLAINTIFF bases the allegation of malice.

74.0 Rent Control and Eviction Control

74.1 Is there an ordinance or other local law in this jurisdiction which limits the right to evict tenants?

74.4 Is this proceeding based on allegations of a need to recover the RENTAL UNIT for use of the LANDLORD or the landlord's relative?

75.0 Breach of Warranty to Provide Habitable Premises

[If plaintiff alleges nonpayment of rent and defendant bases his defense on allegations of implied or express breach of warranty to provide habitable residential premises, then either party may ask any applicable question in this section.]

76.0 Waiver, Change, Withdrawal, or Cancellation of Notice to Quit

77.0 Retaliation and Arbitrary Discrimination

78.0 Nonperformance of the Rental Agreement by Landlord

79.0 Offer of Rent by Defendant

80.0 Deduction from Rent for Necessary Repairs

81.0 Fair Market Rental Value

Printed Name:

Signature:

Date:

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What California Unlawful Detainer Interrogatories Are

California Unlawful Detainer Interrogatories are written discovery questions served in an unlawful detainer (eviction) action to obtain factual information from the opposing party. They are a form of interrogatories governed by California discovery rules and are used to clarify tenancy facts, defenses, and procedural issues before trial. Interrogatories can address rent history, notice receipt, repairs, repair-withhold defenses, payments, and identity or relationship of parties. Properly drafted interrogatories help narrow disputes, preserve evidence, and support dispositive motions or trial preparation in proceedings under California Code of Civil Procedure governing unlawful detainer.

Why these interrogatories matter in eviction cases

Well-crafted Unlawful Detainer Interrogatories reduce surprise at hearing, focus factual issues, and create a verified record that can be used at trial or in dispositive motions.

Why these interrogatories matter in eviction cases

Who typically prepares and responds to these interrogatories

Several parties and professionals routinely use California Unlawful Detainer Interrogatories depending on case role and volume.

  • Landlords and property managers seeking factual details about tenant occupancy, payments, and asserted defenses in preparation for unlawful detainer trial.
  • Tenant attorneys or self-represented tenants using interrogatories to obtain landlord records, notice evidence, and rental payment histories before hearing.
  • Civil litigation attorneys and paralegals who manage discovery, verify answers, and use responses to plan motions or settlement discussions.

Each user must follow California discovery timelines and court rules to avoid waiving objections or incurring sanctions.

Step-by-step: completing and serving interrogatories

Follow a consistent sequence to draft, serve, track responses, and preserve the record for hearing or trial.

  • 01
    Draft Questions: Focus on specific facts; avoid compound or vague phrasing.
  • 02
    Attach Definitions: Include defined terms and instructions to reduce scope disputes.
  • 03
    Serve Documents: Serve per CCP rules and note method and date of service.
  • 04
    Verify Responses: Confirm signatures and preserve copies with timestamps.

Configuring an electronic workflow for interrogatories

Set up templated fields and routing to ensure consistent serving, signing, and storage across cases.

Field Configuration
Template Name Create a reusable interrogatory template for unlawful detainer matters
Signer Roles Assign roles such as 'Respondent' and 'Served Party' with required fields
Verification Field Add a signed verification checkbox and date field for sworn statement
Retention Tag Tag documents with case number, court name, and retention policy

Where to serve and how documents move through the case

Understand each routing step so interrogatory answers are admissible and properly recorded for the unlawful detainer timeline.

  • Prepare Document: Draft interrogatories and add verification signed by the responding party.
  • Serve Opposing Party: Serve via permitted methods and record service date.
  • Receive Responses: Collect signed responses and any exhibits provided.
  • File as Needed: File discovery-related declarations or motions with the court if disputes arise.

Distribution and eSubmission considerations

Choose delivery channels that meet California procedural rules and preserve a reliable audit trail for the court record.

  • Email and Portal: Serve and collect signed answers with secure email or client portals
  • Certified or Overnight: Use certified mail or overnight courier when proof of service is required
  • Platform Integrations: Connect to case management and storage systems for auditability

Maintain clear proof of service and retention metadata to support admissibility during unlawful detainer hearings.

Key timelines and response deadlines to track

Deadlines differ by pleading type and service method; track calendar dates carefully and preserve proof of service for each step.

General Interrogatory Response:

30 days from service under California civil discovery rules

Shortened UD Timelines:

Unlawful detainer hearings run on an accelerated schedule; check local rules

Motion to Compel:

File promptly after meet-and-confer efforts to avoid waiver

Service Proof:

Retain mailing receipts, email headers, or courier tracking for court

Hearing Preparation:

Allow time to incorporate responses into trial exhibits and witness lists

Typical case milestones from service to hearing

A sequential view helps teams monitor deadlines and escalate discovery disputes promptly.

01

Draft and Serve

Serve interrogatories and supporting instructions to opposing parties.

02

Response Period

Opposing party prepares sworn answers or objections within the response window.

03

Meet-and-Confer

Engage to resolve objections before filing motions to compel.

04

File Disputes

File motions and declarations when meet-and-confer fails; prepare for expedited hearing.

Common preparation mistakes to avoid

  • Serving vague or compound interrogatories that invite objections and delay responses, increasing litigation costs and complicating hearings.
  • Failing to attach or reference exhibits and records cited in answers, which weakens evidentiary value and may prompt follow-up discovery.
  • Omitting a proper verification or signature on responses, risking objections to form and potential sanctions for noncompliance.
  • Neglecting to document service method and date, which can lead to disputes about timeliness and procedural compliance at hearing.

Consequences of improper or late responses

Sanctions: Monetary penalties possible
Evidence Exclusion: Answers may be precluded
Waiver: Objections may be waived
Default Risk: Procedural default on issues
Increased Costs: Additional attorney fees likely
Hearing Delay: Case timeline may extend

Essential elements to include in a professional set of interrogatories

A complete interrogatory set is organized, precise, and includes instructions, definitions, exhibit references, verification, and clear service directions.

Clear Definitions

Provide precise definitions for terms like 'you', 'tenant', 'premises', and defined time periods to eliminate ambiguity and reduce objections.

Specific Questions

Use targeted questions on rent history, notice receipt, repairs, and payment records to generate admissible facts and narrow contested issues.

Exhibit References

Identify and attach documents referenced by question number so answers can adopt or authenticate materials without separate foundation.

Verification Clause

Include a signed verification under penalty of perjury to ensure answers are sworn and suitable for evidentiary use at hearing.

Objection Protocol

State that objections must be specific and identify privileged materials with a privilege log when applicable to avoid boilerplate objections.

Service Instructions

List acceptable service methods, address for service, and the date by which responses must be served to avoid timing disputes.

Security and compliance features for electronic handling

Encryption: TLS 1.2/1.3; AES-256 at rest
Audit Trail: Timestamped IP and action log
HIPAA BAA: BAA available where PHI is present
21 CFR Part 11: Support for FDA-regulated workflows
SOC 2: SOC 2 Type II certified
Access Controls: Role-based permissions and SSO

Comparison of eSignature pricing and capabilities

High-level pricing and feature differences for common eSignature providers used to execute legal discovery and sworn verifications.

signNow DocuSign Adobe Sign PandaDoc HelloSign
Starting Price $8/user/mo $15/user/mo $14/user/mo $19/user/mo $15/user/mo
Free Trial 7-day free trial Varies Varies Yes, limited Yes, limited
Bulk Send Yes Yes Yes Yes No
Audit Trail Yes Yes Yes Yes Yes
HIPAA Compliant Yes Yes Yes No No
Envelope Cap No envelope cap 100 envelopes/user/year Varies by plan Varies by plan Varies by plan

Frequently asked questions about Unlawful Detainer Interrogatories

Practical answers to common procedural and technical questions about drafting, serving, and e-signing discovery in California unlawful detainer cases.


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