2. What is the legal meaning of
interrogatories?
In a civil action, an interrogatory is a
list of questions one party sends to
another as part of the discovery
process. The recipient must answer
the questions under oath and
according to the case's schedule.
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3. CONCEPTS
What :written questions to another party to
be answered in writing, under oath , in 30
days
Why: to gather preliminary information
before the trail
When : prior to any discovery device
Scope : broad ,any matter not privilege and
is relevant ,reasonable calculated to lead to
Admissible evidence
Number :typically 25 or 30 it depends to the
jurisdiction you are in & type of the case
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4. What are interrogatories used for?
Interrogatories are a discovery tool
that the parties can use to have
specific questions about a case
answered before trial.
Interrogatories are lists of questions
sent to the other party that must
respond to in writing.
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5. What happens if I don't answer
interrogatories?
Motions to Compel – If a party doesn't
respond to interrogatories or requests
for production, then the party seeking
those answers must file a motion to
compel with the court. If the court
grants the motion to compel, then the
party who objected or failed to answer
must then do so.
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6. Do I have to answer interrogatories?
You have a Deadline for Responding to
Interrogatories.
If you object to some questions in
time, you do not have to answer them
until a judge rules on your objections. If
you only object to specific questions, you
must answer all the other questions by
the deadline.
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7. Are interrogatories mandatory?
You do not need court permission to
serve interrogatories on the other
party. A person served with
interrogatories has thirty days after
service to respond in writing. You
must answer each interrogatory
separately and fully in writing under
oath, unless you object to it.
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9. RELATIVELY LOW COST
No court reporter fees-no filing fees
,no record fees involves ,every law
company has standard
interrogatories to send to save time ,
efforts and cost depending on each
case.
Responding party has duty to seek
out information
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10. DEMERTS
Answers not spontaneous – you have
30 days to answers ,not a good tool
for getting details ,cant easily follow
up
limited numbers ,deposition is better
for spontaneous questions and
follow up.
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11. What is the difference between form
interrogatories and deposition?
Interrogatories are written questions for
which written answers are prepared and
then signed under oath. ... Whereas
depositions are useful for obtaining
candid responses from a party and
answers not prepared in advance,
interrogatories are designed to obtain
accurate information about specific
topics. ezzbassyouni@gmail.com
12. Content
Introductory paragraph- From -to –CASE
Definitions - clear concise questions
Document -
Identify -
you
yours
Instructions
Questions
Attorney signature- certificate of
services ezzbassyouni@gmail.com
13. WHAT TO ASK?
personal info , corporate info
names-present addresses-job
history-date of birth-phones
we want to know your
witnesses to depose them
,interview them
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14. WE MAY ASK ask the other
party's version of the fact ,the
incident .
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15. We may inquire about medical history
,the injuries ,diagnoses, prognosis,
doctors who treat ,the hospital , the
clinics , costs ,bills extra……
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16. DRAFTING TIPS
planning required
does the questions lead to
admissible evidence ?
avoid sub questions
reduce length phrases class words
be mindful of tenses
phrase questions to determine if
information is first hand knowledge
or has been told.
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17. Answering interrogatories
deadline to respond 30 days
objections
not relevant
assistance from client
information beyond my reach ,under
burden
unclear ,need specificity ,
you ask a privilege information I cant
give it to you
sign answer under oath
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