There are two types of interrogatories, form and special interrogatories.
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.
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.
Prepare to write your interrogatories by carefully reading the entire complaint and answer. Your interrogatories will depend heavily on the specific facts of your case and what information you need to obtain from the opposing party. Make a discovery plan before you draft your interrogatories.
Unless otherwise expressly provided by rule of the Supreme Court, whenever in this Code any complaint, petition, answer, reply, bill of particulars, answer to interrogatories, affidavit, return or proof of service, or other document or pleading filed in any court of this State is required or permitted to be verified, ...
For example, Rule 45(c)(1) directs that a party serving a subpoena “shall take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena,” and Rule 45(c)(2)(B) permits the person served with the subpoena to object to it and directs that an order requiring compliance “shall protect a ...
Also, amended Rule 213(d) retains the requirement that “within 28 days after service of the interrogatories upon the party to whom they are directed, the party shall serve a sworn answer or an objection to each interrogatory, with proof of service upon all other parties entitled to notice.
It is the intent of this rule that a party must produce all responsive documents, objects or tangible things in its possession, and fully disclose the party's knowledge of the existence and location of responsive documents, objects or tangible things not in its possession so as to enable the requesting party to obtain ...
Rule 213 - Written Interrogatories to Parties (a)Directing Interrogatories. A party may direct written interrogatories to any other party. A copy of the interrogatories shall be served on all other parties entitled to notice. (b)Duty of Attorney.
Unless otherwise expressly provided by rule of the Supreme Court, whenever in this Code any complaint, petition, answer, reply, bill of particulars, answer to interrogatories, affidavit, return or proof of service, or other document or pleading filed in any court of this State is required or permitted to be verified, ...