Unlike the form interrogatories, special interrogatories are narrowly tailored to your individual case. They have to be written with the particular dates, events, and people involved in your case, and thus require special attention to the details that will make a difference at trial.

Discovery should be done at the earliest opportunity after the motion to quash is finally decided, because things can go quickly after that, such as the shortened hearing on the demurrer. There is a deadline by which all discovery has to be completed, and if the landlord's lawyer tries to stall you with evasive tactics, and you need to file a motion to compel, even that has a deadline to file which you may not meet if you delay in beginning discovery.