Yes! You can use AI to fill out Form DISC-003/UD-106, Form Interrogatories—Unlawful Detainer

Users often forget to fill in crucial identifying information at the top of the form, such as the 'Case Number', 'Asking Party', 'Answering Party', and 'Set No.'. This happens due to oversight when rushing to complete the substantive questions. Missing this information can lead to the document being rejected by the court clerk, misfiled, or considered invalid, causing significant delays in the legal discovery process. To avoid this, double-check that every field in the header is completed accurately before proceeding to the questions. AI-powered tools like Instafill.ai can help by flagging mandatory fields and ensuring they are filled before finalization.

The asking party is required to check the box next to each specific interrogatory they want the answering party to answer. A very common mistake is to draft the document but forget to check these boxes. If the boxes are not checked, the answering party has no legal obligation to respond to those questions, rendering the entire effort useless. To prevent this, the asking party must carefully review the form and mark every relevant question; using a digital tool can help ensure selections are saved correctly.

As per Instruction 3(g), the answering party's responses must be signed and dated under penalty of perjury. Forgetting this verification step is a critical error that invalidates the entire set of answers. This often occurs because the signature line is at the very end of a long document. An unverified response can be stricken by the court, and the party may face sanctions, including having facts deemed admitted against them. Always remember to print, sign, and date the final page of your responses.

Many questions, such as 71.2(c) and 71.8(d), require the party to not only identify a supporting 'DOCUMENT' but also state the name, ADDRESS, and telephone number of the 'PERSON' who has it. Parties frequently mention a document (e.g., 'the lease') but fail to provide the custodian's contact details. This incomplete response prevents the asking party from easily requesting the document in a subsequent production request. To avoid this, always provide the full contact information for whoever possesses the original or a copy of the document.

Section 4 of the form explicitly defines 'RENTAL UNIT' (the specific premises being recovered) and 'PROPERTY' (the entire building or parcel). A frequent mistake is using these terms interchangeably when answering questions like 70.6 ('Are there other rental units on the PROPERTY?'). This confusion leads to inaccurate or ambiguous answers that can weaken a party's position. Carefully read the definitions and apply them precisely throughout your responses to ensure clarity and accuracy.

Interrogatories with multiple sub-parts, like 70.8 regarding security deposits or 75.3 regarding repair notices, are often answered incompletely. A party might answer the main question but neglect to provide all the specific details requested in sub-parts (a), (b), (c), etc. This forces the asking party to file a motion to compel further responses, wasting time and money. To avoid this, address each sub-part of a question separately and completely, ensuring every piece of requested information is provided.

Parties representing themselves ('pro se' or 'pro per') often get confused by the attorney information block. They might leave their own contact information blank or incorrectly try to fill in fields like 'State Bar Number' or 'Firm Name'. This can cause confusion for the court and opposing party regarding who to serve documents on. A self-represented party should enter their own name, address, and phone number and leave the State Bar Number field blank. Using a smart form-filling tool like Instafill.ai can guide users to fill the correct fields based on whether they are an attorney or a self-represented party.

When asked about agreements not in writing (e.g., in question 70.11(b) or 78.1), parties often provide a vague summary like 'we agreed on repairs' instead of the required specifics. The form requires stating each part of the oral agreement, the date it was made, and the name, address, and phone number of each person who agreed to it. Failing to provide this detail makes the claim about the oral agreement difficult to substantiate and may render the answer non-responsive. Be as specific as possible about who said what, to whom, and when.

Instruction 3(e) allows a party to answer an interrogatory by referencing a document, but it requires specificity. A common error is to attach a lengthy document, like a 30-page lease, and simply state 'See attached lease' without directing the asking party to the specific page and section where the answer is located. This is an improper response. To avoid this, your answer must clearly state, for example, 'See attached Rental Agreement, page 3, section 5.1'.

The form defines 'ADDRESS' in Section 4(h) as the full street address, including city, state, and zip code. Throughout the form, parties are asked for addresses of various persons. A frequent data entry error is providing only a street name and number, omitting the city, state, and zip code. This makes the information incomplete and potentially useless for serving notices or contacting individuals. Advanced form-filling tools like Instafill.ai can help prevent this by validating address formats and ensuring all components are included.