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For example, divorce case where custody is at issue and there has been domestic violence will likely have questions centering upon that domestic abuse. A custody case will likely include Interrogatories addressing proposed physical care and visitation schedules, and how each party intends to care for the child.
How to Write Draft Interrogatories Brainstorm questions to ask the non-party related to the issues in the case. Identify relevant documents, witnesses, or other evidence that will be needed to answer the interrogatories. Draft the interrogatories in written form. Ensure the interrogatories are clear, concise and specific.
Discovery requests typically follow a common format that you can mirror. First, list instructions detailing the request for production. Be sure to mention Rule 34 and Rule 26(b), which outline the scope of the discovery request. It's also necessary to include a section with definitions.
You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.
Read each question (interrogatory) very carefully. Answer only the question that is asked, and avoid the temptation to over-explain your answer. If the question contains several parts, you may break your answer into parts as well. It is also possible that you might object to the question.