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How to Write Draft Interrogatories Brainstorm questions to ask the non-party related to the issues in the case. Identify relevant documents, witnesses, or other evidence that will be needed to answer the interrogatories. Draft the interrogatories in written form. Ensure the interrogatories are clear, concise and specific.
What types of questions can I ask in interrogatories? Questions about the other party's position or arguments in the case. Questions about the facts of the case. Questions about the other party's knowledge or understanding of relevant events or circumstances. Questions about the other party's witnesses or experts.
Read the question 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.
Generally, interrogatories are objectionable if they seek information that is not within the scope of discovery as defined in Maryland Rule 402 or Federal Rule 26(b). These are typically requests that are not relevant, unduly burdensome, broad, vague, privileged. or protected by the work product doctrine.
You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.