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Interrogatories are to be raised at a pre-trial stage and must have a close connection with the matter in question, whereas cross examinations have a wider scope of questions that can be asked.

Objections to the competency of a witness or to the competency, relevancy, or materiality of testimony are not waived by failure to make them before or during the taking of the deposition, unless the ground of the objection is one which might have been obviated or removed if presented at that time.

(c) Scope; Use at Trial. Interrogatories may relate to any matters which can be inquired into under Rule 26(b)(1), and the answers may be used to the extent permitted by the rules of evidence.

Interrogatories are a discovery tool that the parties can use to have specific questions about a case answered before trial. Interrogatories are lists of questions sent to the other party that s/he must respond to in writing.

Rule 34 of the Federal Rules of Civil Procedure provides for discovery and inspection of documents and things in the course of developing a case for trial. Subsection (b)(1)(A) states that the request must “describe with reasonable particularity each item or category of items to be inspected.” See Fed.

Whereas depositions are useful for obtaining candid responses from a party and answers not prepared in advance, interrogatories are designed to obtain accurate information about specific topics. Interrogatories can be quicker, less costly, and less complicated than depositions, but there are downsides.

The answers given in interrogatories can be used in court during a trial. The information from the interrogatories saves time in a trial because the basic facts have already been established and do not need to be repeated through questions of the witnesses in court.

What is Order to Compel Discovery? A motion asking the Court to Order a noncompliant party or witness to respond to a proper and duly served discovery request.

Motions to Compel – If a party doesn't respond to interrogatories or requests for production, then the party seeking those answers must file a motion to compel with the court. If the court grants the motion to compel, then the party who objected or failed to answer must then do so.