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.
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.
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.
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.
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.”
Special Interrogatories Cannot be Used to Request Documents. The proper mechanism to have a party produce a document is an inspection demand.
You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.
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.
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.