Service Interrogatories With Documents In Harris
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FAQ
The purpose of this requirement—that defendant have time to obtain counsel before a response must be made—is adequately fulfilled by the requirement that interrogatories be served upon a party with or after service of the summons and complaint upon him.
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.
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.
A photocopy of your form interrogatories must be served on the attorney for the responding party or directly to the responding party if he or she is self-represented (in pro per). Courtesy copies should be served on all other attorneys or self-represented parties in the case.
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.
(a) A defendant may propound interrogatories to a party to the action without leave of court at any time. (b) A plaintiff may propound interrogatories to a party without leave of court at any time that is 10 days after the service of the summons on, or appearance by, that party, whichever occurs first.
The original form interrogatories and signed proof of service should be retained for your records. If the other party does not respond to your requests, you may use these documents to support a motion to have the court compel responses.
Civ. P. 33(b)(1)(B), (3) and (5), and Petitioner never moved to compel a proper verification.” Under Rule 33, answers to interrogatories must be verified and must be signed by the person answering the interrogatory, not only by the party's attorney.
How to respond to Requests for Production Download the blank response template and fill in basic information. Prepare the template for your responses. Read and answer the questions. Sign the document.
Special Interrogatories Cannot be Used to Request Documents. The proper mechanism to have a party produce a document is an inspection demand.
