Special Interrogatories Cannot be Used to Request Documents. The proper mechanism to have a party produce a document is an inspection demand.
Interrogatories can be quicker, less costly, and less complicated than depositions, but there are downsides. Since the questions are written, the witness may have more time to think and craft answers, rather than providing more candid answers during discovery.
There is no form for your answer, but you typically have to respond in a specified format, using paper with numbers down the left-hand side, with your name and address at the top left, the name of the court and of the case, and the case number.
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.
However, the U.S. Supreme Court ruled in Seattle Times Co. v. Rhinehart that “pretrial depositions and interrogatories are not public components of a civil trial. Such proceedings were not open to the public at common law, and, in general, they are conducted in private as a matter of modern practice.”
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.
You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.
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.