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You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.
Objecting to interrogatories State objections simply and clearly. Support your objections with legal authority. An objection should be stated just as it would in a response to a ?meet and con fer? letter, and then into an opposition to a motion to compel. A judge will notice and appreciate this kind of consis tency.
Make it a lead-off ?general objection.? Object to anything that is not relevant to the ?subject matter? (no longer the standard) or not likely to lead to admissible evidence (no longer the standard). Don't say if anything is being withheld on the basis of the objection. Use boilerplate wording from form files.
If you are unable to answer a specific question because you don't know or don't have access to the appropriate information, you must indicate the reasons. You may refer to a previous response when responding to an interrogatory providing the previous response sufficiently answers the later interrogatory.
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.