Colorado Interrogatories and Requests for Production - Personal Injury

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US-PI-0310
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This form is a sample set of interrogatories and requests for production propounded to defendant by the plaintiff in a personal injury action.

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FAQ

However, you can object to interrogatories that call for legal conclusions. You can also object to questions if they are not at all related to the court case. To object, you need to write out the reasons for the objection instead of answering the question.

Rule 33(a), Federal Rules of Civil Procedure, restricts to 25 (including all discrete subparts) the number of interrogatories a party may serve on any other party. Leave of court, which is not routinely given absent stipulation, is required to serve more than 25 interrogatories cumulatively.

Rule 33(d) states that a party electing to respond to an interrogatory by providing electronically stored information must ensure that the interrogating party can locate and identify it ?as readily as can the party served,? and that the responding party must give the interrogating party a ?reasonable opportunity to ...

These are typically requests that are not relevant, unduly burdensome, broad, vague, privileged. or protected by the work product doctrine.

Interrogatories to Parties (a) In General. (1) Availability. Unless otherwise stipulated or ordered by the court, a party may serve on any other party no more than 25 written interrogatories, including all discrete subparts.

You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.

If your case is an unlimited civil case (over $25,000) you may ask up to 35 special interrogatories, but may ask more with a declaration explaining the need for additional requests and a statement that the request is not done for an improper purpose.

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Colorado Interrogatories and Requests for Production - Personal Injury