Legal Question in Business Law in California

First, make sure that your case is a "limited jurisdiction" matter, i.e. filed in the court that hears cases where the dispute is $25,000 or less. The limit to which your question alludes only applies in limited jurisdiction cases.

If you are in a limited jurisdiction case, you can pick 35 things to answer. To the rest, object on the ground that the question or request is beyond the limit set forth in Code of Civil Procedure �94.

The Complaint should state on its cover page whether the case is filed as a limited or an unlimited jurisdiction matter. In addition to the $25,000 requested-damages limitation on limited cases, there are other characteristics that "automatically" push a case into the unlimited category; for example, almost all cases asking for declaratory relief rather than money damages are treated as unlimited jurisdiction matters.(see Code of Civil Procedure section 86(a)(7)).

What you are referring to is the "grab bag" rule in Limited Civil Cases. If your case is not a limited civil case, the rule does not apply to you.

Under the grab bag rule, each party may serve on each adverse party no more than 35 of any combination of interrogatories, requests for admisison or demands for inspection. (Code Civ. Proc., sect. 94, subd. (a).)

The general practice is to answer the first 35, and object to the remainder.