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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.
Interrogatories are most effective for obtaining basic factual data from other parties, such as the identity of proper parties, agents, employees, witnesses, and experts and the identity and location of documents, records, and tangible evidence.
There's no doubt that interrogatories can be very intimidating. Unfortunately, however, you don't have the option to ignore them. If you don't respond to them within a certain amount of time, you can be ordered to do so.
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.
Interrogatories can be quicker, less costly, and less complicated than depositions, but there are downsides. Since the questions are written, the witness may have more time to think and craft answers, rather than providing more candid answers during discovery.