Attorneys should ensure that responses to reasonable discovery requests are timely, organized. Complete and consistent with the obvious intent of the request.Interrogatories are only exchanged between the actual parties in a lawsuit. The parties means the plaintiffs and defendants. A sample notice of serving interrogatories used to prove service of interrogatories in a Florida circuit court civil case. To avoid a nonparty's production of documents without deposition, the party must actually file an "objection. Service of Expert Witness Request for Production directed to defendant's liability expert. Defendant asserted that Fla. You will also need to file a "Notice of Service of Response to an Interrogatory. " You can find this form also at the courthouse.