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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 and answer the questions Read the items in the list very carefully. If the fact that is stated is true, write or check the word ?Admit.? If the fact that is stated is not true, write or check the word ?Deny.?
You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.
(3) Answering Each Interrogatory. Each interrogatory must, to the extent it is not objected to, be answered separately and fully in writing under oath. (4) Objections. The grounds for objecting to an interrogatory must be stated with specificity.
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.