Interrogatories should be brief, simple, particularized, unambiguous, and capable of being understood by jurors when read in conjunction with the answer. They should not be argumentative nor should they impose unreasonable burdens on the responding party.
Draft Interrogatories Strategically Only ask specific questions that address the crux of the matter where possible. Avoid board or vague questions. The opposing party's legal team may simply file objections against these, citing irrelevance, wasting your time. Also, ask questions sequentially.
Interrogatories must be served on the party to whom the interrogatories are directed and copies must be served on all other parties. A certificate of service of the interrogatories must be filed, giving the date of service and the name of the party to whom they were directed.
If your case is a limited civil case ($35,000 or less) you can request up to a total of 35 combined request for admissions, form interrogatories , special interrogatories, and requests for production.
Obtain Detailed Information Create a list of questions you want to ask the opposing party in the case. Make sure the questions you ask are relevant to the case and that they will help you support your side of the case. Ensure that the questions are direct, specific, and clear.
You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.
Interrogatories allow the parties to ask who, what, when, where and why questions, making them a good method for obtaining new information in a case. There are two types of interrogatories: form interrogatories and special interrogatories.
How to respond to form interrogatories Download the blank response template and fill in basic information. Prepare the template for your responses. Read and answer the questions. Sign the document.
Interrogatories to Parties (a) In General. (1) Availability. Unless otherwise stipulated or ordered by the court, a party may serve on any other party no more than 25 written interrogatories, including all discrete subparts.