For interrogatories, action words such as “list,” “describe,” “identify,” or “state” are very useful. You may ask the other side to identify a document but you cannot use this form of discovery to get them to give it to you. Requesting documents requires a different kind of discovery process.
Common objections include: The request is impermissibly compound. The propounding party may ask you to answer only one question with each interrogatory. You may object to any request that asks you to answer two or more different questions in a single request.
Interrogatories shall be answered in writing under oath by the party served, if an individual, or, if the party served is a corporation, a partnership or a sole proprietorship, by an officer, director, member, agent or employee having the information.
Interrogatories are written questions sent by one party in a lawsuit to another party in that same suit, which the responding party must answer under penalty of perjury. Interrogatories allow the parties to ask who, what, when, where and why questions, making them a good method for obtaining new information.
You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.
202.20 Interrogatories. Interrogatories are limited to 25 in number, including subparts, unless the court orders otherwise. This limit applies to consolidated actions as well.
Interrogatories may, without leave of court, be served upon the plaintiff after filing of the complaint and upon any other party with or after service of the summons and complaint upon that party.
Interrogatories are lists of questions sent to the other party that s/he must respond to in writing. You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.