Colorado Pattern Interrogatories: Forms, 30-Question Limit, and 35-Day Deadline

Colorado pattern interrogatories are court-approved, fill-in-the-box sets of written discovery questions that the Colorado Judicial Branch publishes for different kinds of cases. You pick the form that matches your dispute, check the boxes next to the questions you want answered, and serve the form on the other side. Using them is optional, but because the phrasing has already been blessed by the courts, you tend to get fewer objections than with questions you draft yourself.¹

Which Form Fits Your Case

The right form depends on the type of case and the court it’s in. Pick wrong and half the questions won’t apply.

Form 20 for General Civil Cases

Form 20 is the main district court form. It covers the identity of the person answering, background information for individuals and entities, physical and emotional injuries, property damage, lost income, medical history, investigation and surveillance, statutory violations, defenses, the defendant’s contentions in personal injury cases, motor vehicle incidents, and contract disputes.¹

Form 35.4 for Divorce and Custody

If the case is a divorce, legal separation, or custody matter, use Form 35.4. Its questions focus on the finances that drive those cases: property dispositions over $1,000 in the past twelve months, real property transfers in the past three years, and assets held by third parties on your behalf, including bank, retirement, and investment accounts.²

Form 21 and Form 21.1

Form 21 is a second set of pattern interrogatories available under CRCP 33 for civil actions. Form 21.1 is written for medical malpractice cases, with questions aimed at professional standards of care and the treatment provided.³ Both can be used alongside Form 20 when a general civil case has a specialized claim built into it.

Forms 7 and 7A for County and Small Claims Court

County and small claims cases have their own, shorter versions: Form 7 for individuals and Form 7A for businesses.⁴

One boundary worth noting on Form 20: the old insurance coverage section (4.0) was withdrawn in 2017 because insurance information is now disclosed automatically under CRCP 26(a)(1)(D). You don’t need to ask for it.¹

They’re Optional, and You Can Mix Them With Your Own Questions

Nothing requires you to use the pattern forms. The Form 20 instructions say so directly: the interrogatories “are intended for optional use in district courts only” and “are not intended to be used in every case.”¹ You can use pattern questions alone, draft your own, or combine both, as long as the total stays within the numerical limits set by CRCP 16(b)(11) and CRCP 33.

The reason most lawyers lean on the forms is friction. Courts have already approved the wording, so the opposing side has a harder time attacking a question as vague, overbroad, or irrelevant. Custom questions invite more fights before you ever see an answer.

Picking Questions Without Blowing Your 30-Question Budget

Each form is a menu. You check only the boxes you actually want answered and serve the form in that marked-up state. Before you check anything, go through what you already have: medical records, financial statements, police reports, contracts, whatever applies. The point of interrogatories is to fill gaps, not to collect what you already possess.

Why that matters: under CRCP 16(b)(11) and CRCP 33, most civil cases cap each party at 30 interrogatories, including subparts. Every checked box counts. A single question with distinct subparts generally counts as more than one. Careless selection on a long pattern form will burn through 30 questions quickly.

If the case genuinely needs more, you can ask the court to allow it. Judges weigh the complexity of the case, whether the same information is reachable through depositions or document requests, and whether the extra questions are proportional to what’s at stake.⁵ Exceeding the cap without permission usually ends with the other side moving to strike the excess and the judge granting it.

Fill in the caption from your initial filings rather than from memory: court and county, case number, division or courtroom, and the names of all parties.⁶ Clerical errors here slow everything down.

Serving the Interrogatories

Once the form is filled out, serve it on the opposing party. Colorado permits service by mail, by e-service through the court’s electronic filing system, or by other electronic means the recipient has agreed to in writing. Anyone who subscribes to e-filing under CRCP 121 Section 1-26 has already consented to electronic service.⁷ Electronic service is complete on transmission, but it’s not effective if you learn the transmission didn’t actually reach the other party.

Do not file the interrogatories themselves with the court. Under CRCP 5(d), discovery requests and responses stay between the parties unless they later get used in a proceeding or a judge orders otherwise. You do file a certificate of service to prove the delivery happened.⁷

Answering: The 35-Day Clock

A party served with interrogatories has 35 days from service to send written answers to every party who has appeared in the case. The court can lengthen or shorten that period, and the parties themselves can agree in writing to a different schedule under CRCP 29.⁵

The answers must be signed by the person actually providing them, not by the attorney. The form carries a verification stating that the answers are “true and correct to the best of my knowledge, information and belief” under penalty of perjury.¹ When the responding party is a business or other entity, an officer or agent with access to the information can sign. Put each answer directly under its question so the document is easy to read.

Objecting Within the Same 35 Days

The 35-day response window is also your deadline to object. A late objection is waived unless the court excuses the delay for good cause.⁵ A timely objection suspends the duty to answer that part of the question until the court resolves the dispute; no separate motion for a protective order is needed.

Objections have to be specific. Boilerplate like “overly broad and unduly burdensome” won’t hold up. Explain why the question crosses the line: it seeks privileged material, falls outside the scope of discovery under CRCP 26(b)(1), is disproportionate to the needs of the case, or duplicates information already disclosed. The attorney, not the party, signs objections. The proportionality analysis looks at the amount in controversy, each side’s relative access to the information, and whether the burden outweighs the likely benefit.⁵

Keeping Your Answers Current

Answering is not a one-and-done event. Under CRCP 26(e), you must update a prior answer whenever you learn it has become materially incomplete or incorrect, unless the corrected information has already reached the other parties through the discovery process.⁵ The duty runs for the life of the case.

If your financial picture shifts after you answer a domestic relations interrogatory, or a new witness surfaces in a personal injury claim, serve an amended response. A court can exclude undisclosed information at trial, which usually means losing the evidence at the moment it matters most.

What Happens If the Other Side Doesn’t Answer

Missing the 35-day deadline, or sending evasive or incomplete answers, lets the other party file a motion to compel under CRCP 37(a). If the court grants it, the non-compliant party, the attorney, or both will usually be ordered to pay the moving party’s reasonable expenses, including attorney fees, unless the failure was substantially justified.⁵

If a party then ignores the order compelling answers, the sanctions get much heavier. The court can treat disputed facts as established in the moving party’s favor, bar the non-compliant party from supporting or opposing specific claims or introducing certain evidence, strike pleadings in whole or in part, stay the case until compliance, dismiss the case or enter default judgment, or hold the party in contempt. These come on top of the mandatory expense awards.⁵

Default judgment as a discovery sanction is rare and generally reserved for repeated, willful noncompliance. Fee-shifting and evidence exclusion, by contrast, are routine. Answering on time, even if some of those answers come packaged with objections, is almost always the cheaper road.

1
Colorado Judicial Branch. Pattern Interrogatories
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Colorado Judicial Branch. Form 35.4 – Pattern Interrogatories (Domestic Relations)
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Colorado Judicial Branch. Colorado Pattern Interrogatories
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Colorado Judicial Branch. Self-Help Forms
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Colorado Judicial Branch. Colorado Rules of Civil Procedure
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Colorado Lawyer. Rule Change 2023(14)
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Colorado Judicial Branch. Colorado Rules of Civil Procedure