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As the party resisting discovery by objecting to an interrogatory, you have the burden to explain why your objections are proper. To satisfy this burden, you should state your objection with specificity. This means giving specific facts, statutes, or judicial precedent supporting your position.
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.
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.
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.
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.