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.
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.
How to fill out Form Interrogatories Fill in basic information at the top of the form. Provide basic information about your case. Select the questions. On Page 2, check the box next to each question you want to ask your spouse to answer. Make copies. Make 1 copy of the completed Form Interrogatories – Family Law.
Interrogatories Calling for Privileged Information An example of an interrogatory that requests privileged information in a divorce would be, “List all prescriptions you take including prescriber information and dosages.”
Clear and Succinct Language: Writing in an easy-to-understand way without using complex legal terms. Leading Questions: Questions that suggest the desired answer and can be seen as an attempt to influence the party's response. Motion to Compel: A legal request to force the opposing party to answer the interrogatories.
You should respond to each interrogatory in the order received. Start by retyping each interrogatory and then follow each question with your answer. If an answer comes from information you received from other people, you should write that as part of your response. Your answers must be signed under oath.
You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.
The responding party must serve a written response on the requesting party within 30 days after service of the interrogatories, except that a defendant in a suit governed by the Family Code served with a request before the defendant's answer is due need not respond until 50 days after service of the request.
Rule 197.1. Interrogatories (1999) A party may serve on another party no later than 30 days before the end of the discovery period - written interrogatories to inquire about any matter within the scope of discovery except matters covered by Rule 195.