How many questions in a special interrogatory set are we allowed to ask in an unlimited civil case?

Granted, based on your question I have no idea what your case is about, or whether you have, indeed, tried to obtain representation, but as a general caveat: if you have to ask that question, please seriously consider if you are qualified to represent yourself. Best, Melissa Mack, Esq. Alameda, CA

You are allowed to propound a total of 35 special interrogatories in an unlimited jurisdiction case, pursuant to Code of Civil Procedure section 2030.030. If you exceed 35 specially prepared interrogatories, you need to attach a declaration of necessity pursuant to Code of Civil Procedure section 2030.050, which provides: "Any party who is propounding or has propounded more than 35 specially prepared interrogatories to any other party shall attach to each set of those interrogatories a declaration containing substantially the following: DECLARATION FOR ADDITIONAL DISCOVERY I, __________, declare: 1. I am (a party to this action or proceeding appearing in propria persona) (presently the attorney for __________, a party to this action or proceeding). 2. I am propounding to __________ the attached set of interrogatories. 3. This set of interrogatories will cause the total number of specially prepared interrogatories propounded to the party to whom they are directed to exceed the number of specially prepared interrogatories permitted by Section 2030.030 of the Code of Civil Procedure. 4. I have previously propounded a total of __________ interrogatories to this party, of which __________ interrogatories were not official form interrogatories. 5. This set of interrogatories contains a total of __________ specially prepared interrogatories. 6. I am familiar with the issues and the previous discovery conducted by all of the parties in the case. 7. I have personally examined each of the questions in this set of interrogatories. 8. This number of questions is warranted under Section 2030.040 of the Code of Civil Procedure because __________. (Here state each factor described in Section 2030.040 that is relied on, as well as the reasons why any factor relied on is applicable to the instant lawsuit.) 9. None of the questions in this set of interrogatories is being propounded for any improper purpose, such as to harass the party, or the attorney for the party, to whom it is directed, or to cause unnecessary delay or needless increase in the cost of litigation. I declare under penalty of perjury under the laws of California that the foregoing is true and correct, and that this declaration was executed on __________. _____________ (Signature) Attorney for_____________________________________"

One cannot improve on Mr. Chen's answer.

I agree that Attorney Chen has provided an excellent and detailed response. Majority of the time when a proper declaration is attached in support of interrogatories exceeding 35 in mumber, the opposing party accepts the declaration and responds to the the interrogatories even though they exceed 35. However, sometimes the declaration is challenged in a motion - i.e., the opposing party soemtimes challenges the propounding party's declaration that the case is of sufficient complexity as to justify more than 35 interrogatories or that the excess number of interrogatories is being prounded for legitimate discovery reasons rather than for for purposes of harrassment or other improper purpose. If the excess number of interrogatories is challenged, the court will need to make a determination as to which party is correct.

You can ask 35 separate special interrogatories. If you require more, simply ask them, then attach a Declaration of Necessity which briefly explains why you need more than 35 (e.g., it's a complicated, multi-party case, etc.)