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Begin by explaining that the case has reached the discovery stage and what that means. Something like this: At this stage of the pending action, all parties are subject to procedures called ?discovery? that allow each party to obtain information and documents relevant to the case.
(3) Answering Each Interrogatory. Each interrogatory must, to the extent it is not objected to, be answered separately and fully in writing under oath.
The receiving party answers the interrogatories by copying the questions onto a form called ?Responses to Interrogatories? and then responding to each question, signing the document to affirm the information in the responses is true and accurate.
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. To raise an objection, you write ?Responding party objects on the grounds? followed by why you object.
You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.
Your answers to the interrogatories should usually be short, clear, and direct and should answer only the question that is being asked. This is not the time to set out your entire case or defense to the other side. Take the time to make sure your answers are correct and truthful.
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.
They are provided for your information. There is no form for your answer, but you typically have to respond in a specified format, using paper with numbers down the left-hand side, with your name and address at the top left, the name of the court and of the case, and the case number.