Colorado pattern interrogatories are pre-approved sets of written discovery questions published by the Colorado Judicial Branch that parties can serve on each other during a lawsuit instead of drafting every question from scratch. The forms are optional, and the right one depends on the type of case: general civil, domestic relations, medical malpractice, or a county or small claims matter. Whichever form you use, you’re still bound by the same rules on how many questions you can ask, how quickly the other side has to answer, and what happens when they don’t.
Which Pattern Form Fits Your Case
Colorado publishes several forms, each tailored to a category of litigation. Picking the wrong one leads to irrelevant questions and easy objections.
Form 20 for General Civil Cases
CRCP Form 20 is the main form for general civil litigation in district court. It covers identity of the person answering, background on individuals and entities, physical or emotional injuries, property damage, loss of income, medical history, investigation and surveillance, statutory violations, defenses, defendant’s contentions in personal injury cases, motor vehicle incidents, and contract disputes.1Colorado Judicial Branch. Pattern Interrogatories
Form 21 and Form 21.1
Form 21 offers an additional set of pattern interrogatories under CRCP 33 for civil actions.2Colorado Judicial Branch. Colorado Pattern Interrogatories Form 21.1 is specific to medical malpractice, with questions aimed at professional standards of care and the treatment provided by healthcare workers. These forms are used alongside Form 20 when the case involves specialized claims the general form doesn’t fully address.
Form 35.4 for Domestic Relations
Form 35.4 applies to divorce, legal separation, and child custody matters. It focuses on the financial issues that drive most domestic disputes: 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 such as bank accounts, retirement accounts, and investment holdings.3Colorado Judicial Branch. Form 35.4 – Pattern Interrogatories (Domestic Relations)
Forms 7 and 7A for County and Small Claims Court
Pattern interrogatories exist outside district court too. Form 7 is for individuals and Form 7A is for businesses in county and small claims proceedings.4Colorado Judicial Branch. Self-Help Forms They are shorter and simpler than the district court forms.
You Don’t Have to Use Them
The pattern forms are tools, not requirements. Form 20 itself states that the interrogatories “are intended for optional use in district courts only” and “are not intended to be used in every case.”1Colorado Judicial Branch. Pattern Interrogatories You can draft your own questions, use the pattern form as-is, or combine both approaches, so long as you stay within the overall numerical limits under CRCP 16(b)(11) and CRCP 33.
The practical reason to use them is that courts have already blessed the phrasing, which cuts down on objections about vagueness, overbreadth, or relevance. Custom questions invite more fights over wording before you ever get an answer.
How to Fill Out and Serve the Form
Each pattern form works like a menu. You don’t send every question. You check the boxes next to the specific interrogatories you want answered, then serve the form on the other party. Only the questions relevant to the actual claims or defenses should be selected.
Before checking any boxes, review what you already have: medical records, financial statements, police reports, contracts. Knowing your own evidence tells you where the real gaps are and stops you from wasting questions on information you can already prove.
Fill in the case caption exactly as it appears in the initial filings: court name and county, case number, division or courtroom, and the names of all parties.5Colorado Lawyer. Rule Change 2023(14) Errors here create clerical problems that slow the case down.
Service can be made by mail, through the court’s e-filing system, or by other electronic means the recipient has agreed to in writing. Parties who subscribe to e-filing under CRCP 121 Section 1-26 have already consented to electronic service. Note that discovery requests themselves aren’t filed with the court under CRCP 5(d); you file a certificate of service, and the interrogatories stay between the parties unless they’re used later in a proceeding or the court orders otherwise.6Colorado Judicial Branch. Colorado Rules of Civil Procedure
The 30-Question Limit
Colorado caps most civil cases at 30 interrogatories per party, including subparts, under CRCP 16(b)(11) and CRCP 33. Every checked box on a pattern form counts, and a single question with multiple distinct subparts generally counts once for each subpart. Careless selection eats through the budget quickly.
If the case truly needs more, you can ask the court for leave to exceed the limit. Judges look at the complexity of the case, whether the information could come from depositions or document requests instead, and whether the additional questions are proportional to what’s at stake.7Colorado Judicial Branch. Colorado Rules of Civil Procedure Serve extra questions without permission and the opposing side will move to strike them, usually successfully.
Responding to Interrogatories You’ve Been Served
The 35-Day Clock
A party who receives interrogatories has 35 days from service to serve written answers on every party that has appeared. The court can shorten or extend that deadline, and the parties can agree to a different timeline in writing under CRCP 29.7Colorado Judicial Branch. Colorado Rules of Civil Procedure
Verification
The person actually providing the answers signs them, not the attorney. The verification declares that the answers are “true and correct to the best of my knowledge, information and belief” under penalty of perjury.1Colorado Judicial Branch. Pattern Interrogatories For a business or other entity, any officer or agent with access to the information can sign. Place each answer directly under its corresponding question.
Objections
The 35-day window is also the objection deadline. Miss it and the objection is waived unless the court excuses the delay for good cause.7Colorado Judicial Branch. Colorado Rules of Civil Procedure A timely objection pauses the duty to answer the objected-to part of the question until the court rules; no separate motion for a protective order is required.
Objections have to be specific. Generic language like “overly broad and unduly burdensome” won’t hold up. Explain why: the question 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 signs objections; the party signs answers.7Colorado Judicial Branch. Colorado Rules of Civil Procedure A pattern question can also be objected to on relevance or proportionality grounds despite being pre-approved.1Colorado Judicial Branch. Pattern Interrogatories
The Ongoing Duty to Supplement
Answering isn’t a one-time event. Under CRCP 26(e), you have to update a prior response when you learn it has become materially incomplete or incorrect, unless the corrective information has already reached the other parties through the discovery process.7Colorado Judicial Branch. Colorado Rules of Civil Procedure The duty lasts through the life of the case.
Practically, that means new evidence contradicting your earlier answer requires an amended response. A changed financial picture in a domestic relations case, or a newly identified witness in a personal injury case, has to be disclosed. Fail to supplement and the court can exclude the undisclosed information at trial, which often means losing the evidence when it matters most.
What Happens If You Don’t Respond
Missing the deadline or giving evasive answers exposes you to a motion to compel under CRCP 37(a). If the court grants it, the non-compliant party, the attorney, or both will typically be ordered to pay the moving party’s reasonable expenses and attorney fees unless the failure was substantially justified.7Colorado Judicial Branch. Colorado Rules of Civil Procedure
Ignoring the order compelling answers raises the stakes further. The court can:
- Treat the requesting party’s version of disputed facts as established.
- Bar the non-compliant party from supporting or opposing specific claims or introducing certain evidence.
- Strike part or all of the disobedient party’s pleadings.
- Stay the proceedings until the party complies.
- Dismiss the case or enter default judgment against the non-compliant party.
- Hold the party in contempt of court.
These sanctions come on top of the mandatory expense award.7Colorado Judicial Branch. Colorado Rules of Civil Procedure Default judgment as a discovery sanction is rare and usually reserved for repeated, willful noncompliance, but fee-shifting and evidence exclusion happen routinely. Answering on time, with objections where they belong, is always the cheaper path.