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Interrogatories are often preferable to depositions for identi- fying such things as witnesses, documents, the dates and sub- stance of transactions and conversations,3 since a deponent may easily forget or overlook relevant information when an- swering such questions.
Read each question (interrogatory) very carefully. Answer only the question that is asked, and avoid the temptation to over-explain your answer. If the question contains several parts, you may break your answer into parts as well. It is also possible that you might object to the question.
Thus, all contention interrogatories should be written with one or two objec- tives in mind: (1) the answers to conten- tion interrogatories can be used to support a summary judgment or other limit on trial, i.e., to limit the defense to the facts, witnesses and documents set forth in their answers to interrogatories ? ...
Each interrogatory shall be answered separately and fully in writing under oath, unless it is objected to, in which event the reasons for objection shall be stated in lieu of an answer.
(8) Interrogatories shall be answered by affidavit to be filed within ten days, or within such other time as the court may allow.