Write out each question as simply as possible. It may be useful to include information such names or dates to make your question clear. You can ask up to 25 interrogatories during the case. You do not have to ask them at all once.
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.
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.
If the opposing side does not respond to your form interrogatories, special interrogatories, or request for production, you may file a motion seeking an order compelling the opposing party to respond.
Usually, lawyers use interrogatories to obtain detailed information about persons, corporations, facts, witnesses, and identity and locations of records and documents. Court rules usually limit the number of questions included in an interrogatory.
(b) Failure to Comply with a Court Order. (1) Sanctions Sought in the District Where the Deposition Is Taken. If the court where the discovery is taken orders a deponent to be sworn or to answer a question and the deponent fails to obey, the failure may be treated as contempt of court.
If the opposing side does not respond to your form interrogatories, special interrogatories, or request for production, you may file a motion seeking an order compelling the opposing party to respond.
Common objections include: The request is impermissibly compound. The request is vague, ambiguous or unintelligible. The request is not reasonably calculated to lead to the discovery of relevant, admissible evidence. Introduction to Discovery – Part 5: Responding to Form Interrogatories.
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.