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Form interrogatories are interrogatories that have not been tailored to the specific facts of a given civil case, and are generally designed to address typical issues that arise in a particular type of litigation (i.e., personal injury, contract disputes, employment, etc.).
Your answers to these interrogatories must be verified, dated, and signed. You may wish to use the following form at the end of your answers: You may insert your own definition of INCIDENT in Section 4, but only where the action arises from a course of conduct or a series of events occurring over a period of time.
Contents hide 7.1 Irrelevant. 7.2 Privilege or Work Product Protection. 7.3 Overbroad. 7.4 Excessive Number. 7.5 Unduly Burdensome, Expensive, or Oppressive. 7.6 Vague and Ambiguous. 7.7 The Information is Already Known or Equally Available to the Requesting Party. 7.8 Speculation or Question Based on an Improper Assumption.
Contention interrogatories can be characterized as: any question that asks another party to indicate what it contends . . . a question asking another party whether it makes some specified contention . . . a question asking an opposing party to state all facts on which it bases some specified contention . . .
How To Write Interrogatories Local Rules. Step one: Read the local rules.Subparts and Compound Questions. Again, you need to head to your local rules and see how they handle compound questions.Tailored Definitions.Tailored Definitions Relating to Documents.Vague Interrogatories Beget Vague Responses.Detail Oriented.
Their use was usually the first volley in the discovery battle. For years the Courts had found that the Form Interrogatories were objection proof as to form with minor exceptions.
Although they are not generally used for purposes of evidence in a trial, they might be admissible if they satisfy the RULES OF EVIDENCE, such as the best evidence rule or are an exception to the HEARSAY rule.
Responses to interrogatories must be verified unless the responding party is not the only party who knows the answer to the question posed and/or if the information is available from another source.
Under the Federal Rules and parallel state rules, litigants may use what are called "contention interrogatories" to explore adversaries' factual support for their legal contentions. Courts normally regulate the timing of those, generally prohibiting litigants from using that tactic too early in the discovery process.
There are two types of interrogatories: form interrogatories and special interrogatories.