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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.
Time after time, courts have authorized sanctions for false and misleading discovery responses, up to and including striking the pleading of the offending party.
As the party resisting discovery by objecting to an interrogatory, you have the burden to explain why your objections are proper. To satisfy this burden, you should state your objection with specificity. This means giving specific facts, statutes, or judicial precedent supporting your position.
If the opposing side does not respond to your form interrogatories, special interrogatories, or request for production, you may file a motion seeking an order compelling the opposing party to respond. This Guide provides step-by-step instructions for seeking such an order.
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.
You have to respond to interrogatories in writing to the best of your ability. If you do not answer an interrogatory question, and then the other side learns that you did in fact know the answer, it could have a negative impact on your case at trial.
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.
If you do not answer the questions by the deadline, which is usually about a month, the other side could ask the judge to order you to respond to the interrogatories. If you miss the second deadline, the judge could impose a fine against you or strike your pleadings.