Sample Letter for First Set of Interrogatories - Production of Documents
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How to fill out Sample Letter For First Set Of Interrogatories - Production Of Documents?
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FAQ
Personal/Corporate information of opposing party. Identifying information of witnesses. Contact information & background of expert witnesses. Insurance information.
Have a strategy. Adjust the scope of your requests to the questions at issue. Send clear requests. Always consider how your client would be prepared to respond to similar requests. Make your objections clear and specific.
The issues discussed above in connection with interrogatories are also the issues which you need to cover in your requests for production. However, because requests for production do not yield a written answer, you can ask both for specific documents and for general categories of documents.
Interrogatories, which are written questions about things that are relevant or important to the case. (NRCP 33; JCRCP 33) Requests for production of documents or things, which are written requests that demand the other side provide particular documents or items.
What Is a Request for Production of Documents? A request for production is a discovery device used to gain access to documents, electronic data, and physical items held by an opposing party in a legal matter. The aim is to gain insight into any relevant evidence that the opposing party holds.
Be alert to possible objections while you're drafting. Ask about particular contentions. Refer to allegations in the pleading. Ask for facts on which the contention is based.
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.
A: Assuming that I draft about 30 - 40 questions per set, and assuming that I can re-use some of my special interrogatories from other past cases, then maybe 2 - 3 hours of my time to prepare a set of special interrogatories. Then another 1 - 2 hours afterward to review and discuss their responses with you.
In law, interrogatories (also known as requests for further information) are a formal set of written questions propounded by one litigant and required to be answered by an adversary in order to clarify matters of fact and help to determine in advance what facts will be presented at any trial in the case.
