Contention Interrogatories "seek all facts that support a particular contention." When modified "to seek 'the material or principal facts' instead of 'all facts'" they may be appropriate for a Motion to Compel. See Download Mancini v. Insurance Corporation of New York (S.D. Cal. Order of Stormes, United States Magistrate Judge, Filed June 18, 2009)(modifying otherwise potentially impermissible "contention interrogatories" accordingly and, as modified, granting Motion to Compel "these interrogatories as modified," reasoning that "[w]hile contention interrogatories are proper, they can impose a large burden. Contention interrogatories are often overly broad and unduly burdensome when they require a party to state 'every fact' or 'all facts' supporting identified allegations or defenses."), attached Official Slipsheet Opinion at 4-5.
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