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Discovery requests typically follow a common format that you can mirror. First, list instructions detailing the request for production. Be sure to mention Rule 34 and Rule 26(b), which outline the scope of the discovery request. It's also necessary to include a section with definitions.
How to Write Draft Interrogatories Brainstorm questions to ask the non-party related to the issues in the case. Identify relevant documents, witnesses, or other evidence that will be needed to answer the interrogatories. Draft the interrogatories in written form. Ensure the interrogatories are clear, concise and specific.
Some examples of the types of questions that you might ask in interrogatories include: Questions about the other party's position or arguments in the case. Questions about the facts of the case.
You have 30 days to respond to Form Interrogatories. If you were served by mail, you typically have 35 days from the date of mailing to respond. In eviction (unlawful detainer) cases the time is much shorter. In eviction cases you have 5 days to respond, or typically 10 days from the date of mailing if served by mail.
You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.
How to use Special Interrogatories Download a template for Special Interrogatories. There are many different templates available for Special Interrogatories. ... Fill out basic information at the top. ... Add your own definitions (if useful) ... Write your questions (interrogatories) ... Sign and date the document. ... Make copies.
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.
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.