This form is a sample set of interrogatories and requests for production propounded to defendant by the plaintiff in a personal injury action.
Kentucky Interrogatories and Requests for Production - Personal Injury
State:
Multi-State
Control #:
US-PI-0310
Format:
Word;
Rich Text
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How to fill out Interrogatories And Requests For Production - Personal Injury?
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FAQ
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.
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 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.
These are typically requests that are not relevant, unduly burdensome, broad, vague, privileged. or protected by the work product doctrine.
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.
You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.
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 ...