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Use Clear and Succinct Language Use language that is understandable, yet concise. Use language that is specific enough to the facts of the case. Avoid using any jargon or legal terms that are not necessary. Keep answers to interrogatories limited to ??yes?? or ??no??, if possible.
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.
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.
Since the questions are written, the witness may have more time to think and craft answers, rather than providing more candid answers during discovery. There is also no chance for back and forth questioning in an interrogatory, unless a subsequent deposition is scheduled.
If the court grants leave or the party consents, you can deliver interrogatories to any party in the action and they must be replied to within 21 days of delivery. Answers to interrogatories are delivered in the form of an affidavit, so the party answering the questions swears to the truth of the answers.
Unlike deposition testimony, which a witness provides in her own voice, interrogatory answers are likely to be written by lawyers. ingly, a lawyer drafting interrogatories needs to draft them carefully so that a clever lawyer does not evade the question because it was written imprecisely.