This is a sample of a Plaintiff's Motion to propound more than 40 interrogatories on the Defendant and a Motion to Compel responses to earlier discovery requests.
This is a sample of a Plaintiff's Motion to propound more than 40 interrogatories on the Defendant and a Motion to Compel responses to earlier discovery requests.
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Step 1: Carefully Review All the Requests. Review each request to ensure you fully understand the question, and can answer it completely.Step 2: Complete Your Responses to the Interrogatories.Step 3: Make Photocopies.Step 4: Have Your Responses Served.Step 5: Retain Your Documents.
1. Identify all persons answering or supplying information used in answering these Interrogatories. 2. State the name, address, and business telephone number of each person with personal knowledge regarding the facts and circumstances surrounding the happenings of the occurrences referred to in the complaint.
Your answers to the interrogatories should usually be short, clear, and direct and should answer only the question that is being asked. This is not the time to set out your entire case or defense to the other side. Take the time to make sure your answers are correct and truthful.
Written interrogatories are also the ideal discovery device where the information sought can be obtained only by reference to several documents or where the information is of such a complex and technical nature that it cannot be communicated verbally in an organized and compre- hensible manner.
Your answers to the interrogatories should usually be short, clear, and direct and should answer only the question that is being asked. This is not the time to set out your entire case or defense to the other side. Take the time to make sure your answers are correct and truthful.