This form is a sample set of interrogatories and requests for production propounded to defendant by the plaintiff in a personal injury action.
Hawaii Interrogatories and Requests for Production - Personal Injury
State:
Multi-State
Control #:
US-PI-0310
Format:
Word;
Rich Text
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FAQ
You can object to an interrogatory if the information sought is known by the requesting party or available to both parties equally. For example, you should raise this objection if the answers are publicly available or in a third-party's custody or control.
Interrogatories, which are written questions about things that are relevant or important to the case. (NRCP 33; JCRCP 33) Requests for production of documents or things, which are written requests that demand the other side provide particular documents or items. (NRCP 34; JCRCP 34.)
The grounds for objecting to an interrogatory must be stated with specificity. Any ground not stated in a timely objection is waived unless the court, for good cause, excuses the failure. (5) Signature. The person who makes the answers must sign them, and the attorney who objects must sign any objections.
You use different types of discovery requests to get different kinds of information: To ask the other side to answer a set of questions, you can use Interrogatories. To ask the other side to admit that certain facts are true or certain items are authentic, you can use Request for Admission.
Common objections to requests for production or inspection include: The request is overly broad or unduly burdensome. ... The request is vague, ambiguous, or unintelligible. ... The request is not reasonably calculated to lead to the discovery of relevant, admissible evidence.
These are typically requests that are not relevant, unduly burdensome, broad, vague, privileged. or protected by the work product doctrine.
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.
You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.