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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.
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.
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.
In civil procedure, an interrogatory is a list of written questions one party sends to another as part of the discovery process. The recipient must answer in writing under oath and ing to the case's schedule.
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.
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.
Have your client verify the interrogatories. Federal Rule of Civil Procedure 33(b)(5) requires the attorney to sign the objections and the client to sign the answers. Do not make a habit or practice of sending interrogatory responses without verifications.
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.