Sample interrogatories to defendant

Sample interrogatories to defendant DEFAULT

{City}, {State} {ZIP}
{Facsimile: }

{Lawyer Name (Bar No.)}
Email: {}

Attorney for Plaintiff

In the Superior Court of the state of Arizona
In and for the County of Maricopa






Case No.: ____________________________





Tier [1, 2 or 3][Tier 1 – Select 5; Tier 2 – Select 10; Tier 3 – Select 20]



Plaintiff, by and through undersigned counsel and pursuant to Rule 33 & 33.1, Arizona Rules of Civil Procedure, requests that the Defendant answer, under oath and in writing within thirty (30) days after service, the following Interrogatories:

    1. State your name and address or principal place of business, date of birth and social security number.
    2. Have you been convicted of a felony? ______If so, for each felony state:
      1. The original charge made against you.
      2. The charge of which you were convicted.
      3. Did you plead guilty of the charge or were you convicted after trial?
      4. The court and cause number.
    3. Have you ever been a party to a civil lawsuit? ______If so state:
      1. Were you plaintiff or defendant?
      2. What was the nature of the plaintiff’s claim?
      3. When, where, and in what court was the action commenced?
      4. State the names of all the parties other than yourself.
    4. State exactly and in detail your version of how this accident occurred.
    5. State specifically and in detail the facts upon which your contention is based that the accident was caused by a negligent conduct of another party, including former parties, or non-party.
    6. Was an investigation conducted concerning the accident in question? ______If so state:
      1. The name, address, and occupation of the person or organization conducting the investigation.
      2. The date or dates on which the investigation was conducted.
      3. Whether you or anyone acting on your behalf has interviewed or spoken with any other party or any of its agents or employees about the event in question. ______If so, please identify the individual spoken with and the substance of the conversation.
      4. The name and address of the person now having custody of any written report made concerning the investigation.
    7. Do you know of any person who is skilled in any particular field or science, including the field of medicine, whom you may call as a witness upon the trial of this action and who has expressed an opinion upon any issue of this action? ______If so state:
      1. The name and address of each person.
      2. The field or science in which each such person is sufficiently skilled to enable opinion evidence in this action.
      3. Whether such potential witness will base his or her opinion:
        (1) In whole or in part upon facts acquired personally by him or her in the course of an investigation or examination of any of the issues of this case, or
        (2) Solely upon information as to facts provided him or her by others.
      4. If your answer to 7(C) discloses that any such witness has made a personal investigation or examination relating to any of the issues of this case, state the nature and dates of such investigation or examination.
      5. Each and every fact, and each and every document, item, photograph or other tangible object supplied or made available to such person.
      6. The general subject upon which each such person may express an opinion.
      7. Whether such persons have rendered written reports. ______If so:
        (1) Give the dates of each report.
        (2) State the name and address of the custodian of such reports.
    1. Describe in detail all injuries, whether physical, mental or emotional, experienced since the occurrence and claimed to have been caused, aggravated, or otherwise contributed to by it.
    2. For all injuries mentioned in the proceeding interrogatory, please identify those injuries which are considered by you to be permanent.
    3. As to each medical practitioner who has examined or treated any of the persons named in your answer to Interrogatory No. 1 above, for any of the injuries or symptoms described, state:
      1. The name, address and specialty of each medical practitioner.
      2. The date of each examination or treatment.
      3. The physical, mental, or emotional condition for which each examination or treatment was performed.
    4. State as to each item of medical expense attributable to the accident:
      1. The name and address of the person or organization paid or owed for the medical expense.
      2. The amount.
      3. The date of each item of expense (attach copies of the itemized bills, if desired).
      4. The person or organization who paid the medical expense.
      5. The condition for which you incurred the expenses.
      6. Will you incur medical expenses in the future as a result of the accident in question? ______If so, state the amount of medical expenses which will be incurred in the future and state in detail the knowledge and source upon which you rely in support of this belief.
    5. List each injury, symptom, or complaint mentioned in answer to Interrogatory No. 8 from which you suffered at any time before the accident.
    6. Do you claim to have lost any time from gainful employment as a result of the accident? ______If so state:
      1. The specific condition which you claim caused the loss of time.
      2. The amount of time lost.
      3. The rate of pay or compensation regularly received from each such gainful employment.
      4. If you claim any damage as a result of the time lost, the total and your method of computation.
    7. If your answer to Interrogatory No. 13 is yes, list each job or position of employment including self-employment, held by you on the date of and since the accident, stating as to each, the following:
      1. Name and address of employment.
      2. Date of commencement of and date of termination.
      3. Place of employment.
      4. Nature of employment and duties performed.
      5. Name and address of immediate supervisor.
      6. Rate of pay or compensation received.
    8. Do you claim that your ability to engage any type of gainful employment has been affected by the accident? _____If so state:
      1. The specific condition which limits your ability to engage in gainful employment.
      2. The economic loss caused by your inability to find gainful employment.
      3. Your method of computation for computing such loss.
    9. Provide the identity and location of any nonparty identified in your response to Interrogatory No. 5 above, who you claim, pursuant to A.R.S. § 12-2506(B) (as amended), was wholly or partially at fault in causing any personal injury, property damage, or wrongful death for which damages are sought in this action.
    10. Do you have liability insurance or are you aware of any other form in indemnity which you claim is applicable to this accident? _____ if the answer is yes, state:
      1. The name of the company or companies, including any excess or umbrella carriers, which you claim provide coverage.
      2. The policy number or numbers of any applicable policy.
      3. The limit or limits of liability of each policy.
      4. The named insured on each policy.
      5. Whether the insurance carrier has accepted or denied coverage.
      6. Whether you are being defended by the insurance carrier under a reservation of rights.
    11. State the name, address, and occupation of the owner of any vehicles you allege caused damage to the plaintiff.
    12. At the time of the alleged accident, was the driver of said vehicle engaged in the business of any other person or entity? _____ If so, please state the name and address of such other person or entity.
    13. State whether you or anyone else involved in the accident ingested or used any drugs or medications within 48 hours prior to the accident or drank any intoxicating beverages of any kind within the 12 hours prior to the accident or to the occurrence of the accident alleged in the Complaint. _____ If so, state the times, places, amount, and type of drugs or alcoholic beverages.
    14. Do there exist any liens, including AHCCCS, Medicare, or any liens provided for by A.R.S. §33-931 et seq., on any recovery you may have or may obtain in this matter? _____ If so, give the amount and entity holding such lien and the nature of said lien.
    15. If the accident that is the subject of plaintiff’s claim was an automobile accident, please state the following:
      1. Did the vehicle which you were occupying at the time of the accident contain operational seatbelts? _____ If so, were you wearing seatbelts available for your use? _____

      If you were not wearing the seatbelts available for your use in the vehicle at the time of the accident, set forth your reasons for failing to do so.

DATED this ____ day of _____________, _____.




{law firm name}


{Law Firm Address}

{City} {Arizona}, {Zip}

Attorney for Plaintiff



ORIGINAL of the foregoing mailed this

____ day of ___________ 20__, to:


{Name of Opposing Counsel}


{City}, {State} {Zip}

Attorney for Defendant


By ___________________________________


Plaintiff's First Set Of Interrogatories To Defendant







Civil Action No. 99-005 (MMS)


Pursuant to Fed. R. Civ. P. 33, Plaintiff hereby submits the following Interrogatories to Defendant. Plaintiff requests that Defendant serve its answers, in writing and under oath, to the undersigned counsel for Plaintiff at 325 Seventh Street, N.W., Room 400, Washington, D.C. 20530, within 30 days of service of these Interrogatories.

For the purpose of these Interrogatories only, Plaintiff has used the definitions set forth below.

I.   Definitions

As used in these Interrogatories:

1. "Agreement" means a contract, arrangement, or understanding, formal or informal, oral or written, between two or more persons.

2. "Any" means one or more.

3. "Base materials" means acrylic or any similar substance used in connection with prefabricated artificial teeth to make dentures.

4. "Communication" means any disclosure, transfer, or exchange of information or opinion, however made.

5. "Dealer" means any person that distributes any dental products of any other person or purchases or acquires any such product for the sole purpose of reselling such products to any other person, such as a dental laboratory, dentist, dental school or government entity.

6. "Dental laboratory" means any person that prepares, constructs, assembles or otherwise fills an order or prescription from a dentist for dentures or any other removable or fixed dental prosthetic device, and includes any group, chain or organization of dental laboratories.

7. "Dentsply" means Dentsply International, Inc., each of its predecessors (including Gendex Corporation), successors, divisions, subsidiaries, and affiliates, located both in the United States and in any other country, each other person directly or indirectly, wholly or in part, owned or controlled by it, and each joint venture to which any of them is a party, and all present and former directors, officers, employees, agents, consultants, or other persons acting for or on behalf of any of them.

8. "Denture" means artificial teeth fixed in a base material used to replace some or all of a patient's natural teeth.

9. The phrase "describe in detail" as used in these interrogatories includes a request for a complete description and explanation of the facts, circumstances, analysis, opinion and other information relating to (as that phrase is defined below) the subject matter of a specific interrogatory.

10. "Document" means any written, recorded, or graphic material of any kind, whether prepared by you or by any other person, that is in your possession, custody, or control. The term includes agreements; contracts; letters; telegrams; inter-office communications; memoranda; reports; records; instructions; specifications; notes; notebooks; scrapbooks; diaries; plans; drawings; sketches; blueprints; diagrams; photographs; photocopies; charts; graphs; descriptions; drafts, whether or not they resulted in a final document; minutes of meetings, conferences, and telephone or other conversations or communications; invoices; purchase orders; bills of lading; recordings; published or unpublished speeches or articles; publications; transcripts of telephone conversations; phone mail; electronic-mail; ledgers; financial statements; microfilm; microfiche; tape or disc recordings; and computer print-outs.

The term "document" also includes electronically stored data from which information can be obtained either directly or by translation through detection devices or readers; any such document is to be produced in a reasonably legible and usable form. The term "document" includes all drafts of a document and all copies that differ in any respect from the original, including any notation, underlining, marking, or information not on the original. The term also includes information stored in, or accessible through, computer or other information retrieval systems (including any computer archives or back-up systems), together with instructions and all other materials necessary to use or interpret such data compilations.

Without limitation on the term "control" as used in the preceding paragraph, a document is deemed to be in your control if you have the right to secure the document or a copy thereof from another person.

11. "Exclusive arrangement with a dealer" means any proposed or actual agreement, arrangement, policy, program, practice, term or condition of your company that:

a. requires any dealer to limit the scope or intensity of effort, or refrain from service, as a dealer for the products of any other person; or

b. has the purpose or effect of encouraging any dealer to limit the scope or intensity of effort, or refrain from service, as a dealer for the products of any other person.

12. "Exclusive arrangement with a dental laboratory or dentist" means any proposed or actual agreement, arrangement, policy, program, practice, term or condition of your company that:

a. requires any dental laboratory or dentist to limit the use of, or refrain from using, the products of any other person; or

b. has the purpose or effect of encouraging any dental laboratory or dentist to limit the use of, or refrain from using, the products of any other person.

13. "Identify" or "identity" means to state or a statement of:

a. in the case of a person other than a natural person, its name, the address of its principal place of business (including zipcode), its telephone number, and the name of its chief executive officer, as well as, if it has a person other than a natural person that ultimately controls it, that other person's name, the address of that person's principal place of business (including zipcode), that other person's telephone number, and the name of that other person's chief executive officer;

b. in the case of a natural person, his or her name, business address and telephone number, employer, and title or position;

c. in the case of a communication, its date, type (e.g., telephone conversation or discussion), the place where it occurred, the identity of the person who made the communication, the identity of the person who received the communication, the identity of each other person when it was made, and the subject matter discussed;

d. in the case of a document, the title of the document, the author, the title or position of the author, the addressee, each recipient, the type of document, the subject matter, the date of preparation, and its number of pages; and

e. in the case of an agreement, its date, the place where it occurred, the identity of all persons who were parties to the agreement, the identity of each person who has knowledge of the agreement and all other persons present when it was made, and the subject matter of the agreement.

14. "Including" means including, but not limited to.

15. "Person" means any natural person, corporation, company, partnership, joint venture, firm, association, proprietorship, agency, board, authority, commission, office or other business or legal entity, whether private or governmental.

16. "Prefabricated artificial teeth" or "teeth" means any prefabricated (as opposed to dental laboratory or dentist constructed) product used in a denture or as an implant to replace one or more natural teeth.

17. "Relating to" means containing, constituting, considering, comprising, concerning, discussing, regarding, describing, reflecting, studying, commenting or reporting on, mentioning, analyzing, or referring, alluding, or pertaining to, in whole or in part.

18. "Relevant time period" means the time period stated in paragraph 1 of the Instructions.

19. "Shade guide" means any device used to match the color or shade of prefabricated artificial teeth to a patient's natural teeth for the specifications contained in a dentist's prescription for dentures or any other removable or fixed dental prosthetic device.

20. "Year" means calendar year or the twelve-month period on which your business records are based; if the latter is used in responding to a interrogatory, specify the twelve month period used.

21. "You," "your" or "your company" means Dentsply.

22. The singular form of a noun or pronoun shall be considered to include within its meaning the plural form of the noun or pronoun, and vice versa; and the past tense shall include the present tense where the clear meaning is not distorted. The term "or" shall mean "and" and vice-versa, as necessary to bring within the scope of the following interrogatories all information or documents that would be excluded absent this definition.

II.   Instructions

1. Unless otherwise specified, these interrogatories are limited to the time period from January 1, 1995, to and including the date of service of these interrogatories.

2. Unless otherwise specified, the information called for by these interrogatories is limited in scope to information relating to supplying, manufacturing, distributing, selling, or advertising or promoting products in the United States. For any paragraph that requests information relating to supplying, manufacturing, distributing, selling, or advertising or promoting products in any country other than the United States, the information called for includes all information in your possession, custody or control maintained in both the United States or in any other country.

3. Where knowledge, information, or documents are requested, such request encompasses knowledge, information or documents in your possession, custody or control, or in the possession, custody or control of your staff, agents, employees, representatives and, unless privileged, attorneys, or any other person who has possession, custody or control of your proprietary knowledge, information or documents.

4. Pursuant to Fed. R. Civ. P. 26(e), you are under a duty seasonably to amend any answer to these interrogatories for which you learn that the answer is in some material respect incomplete or incorrect and if the additional or corrective information has not otherwise been made known to us during the discovery process or in writing.

5. For any interrogatory or part of an interrogatory which you refuse to answer under a claim of privilege, submit a sworn or certified statement from your counsel or one of your employees in which you identify the nature of the information withheld; specify the grounds of the claimed privilege and the paragraph of these interrogatories to which the information is responsive; and identify each person to whom the information, or any part thereof, has been disclosed.

6. Answer each interrogatory fully. If you object to any interrogatory, state the reasons for objection and answer to the extent the interrogatory is not objectionable. If you are unable to answer an interrogatory fully, submit as much information as is available, explain why your answer is incomplete, and identify or describe all other sources of more complete or accurate information.

7. For any record or document responsive or relating to these interrogatories which is known to have been destroyed or lost, or is otherwise unavailable, identify each such document by author, addressee, date, number of pages, and subject matter; and explain in detail the events leading to the destruction or loss, or the reason for the unavailability of such document.

8. No agreement, understanding, or stipulation by the Department of Justice or any of its representatives purporting to modify, limit, or otherwise vary these interrogatories shall be valid or binding on the Department of Justice unless confirmed or acknowledged in writing (or made of record in open court) by a duly authorized representative thereof.

III.   Interrogatories

1. State your company's annual unit and dollar sales separately for each type or line of prefabricated artificial teeth that your company sold or manufactured for each year during the relevant time period.

2. State your company's annual unit and dollar sales, separately for each type or line of prefabricated artificial teeth your company sold or manufactured in any country other than the United States, separately for each such country, and separately for 1985 and each subsequent year.

3. Separately for 1997 and each subsequent year, describe in detail and quantify each separate cost or expense relating to training or educating dealers' personnel, dental laboratories' personnel, and dentists, and to the extent possible, allocate the costs and expenses between dealers, dental laboratories, and dentists.

4. Separately for 1997 and each subsequent year, describe in detail and quantify all fees and other income Dentsply collected from third parties relating to training or educating dealers' personnel', dental laboratories' personnel, and dentists, and to the extent possible, allocate the fees and other income between dealers, dental laboratories, and dentists.

5. Separately for 1990 and each subsequent year through 1996, describe in detail and quantify each separate cost or expense, and all fees and other income Dentsply collected from third parties, relating to training or educating dentists.

6. Describe in detail and quantify your company's costs or expenses attributable to each dealer to whom you sell prefabricated artificial teeth, separately for each year, and separately for each such dealer, including but not limited to administrative, transactional or other costs or expenses relating to tooth returns or exchanges, drop-shipments, inventory management (including computer hardware or software provided to dealers by Dentsply), training, sales support, marketing, or advertising.

7. State the marginal cost of production of each type or line of prefabricated artificial teeth that your company sold or manufactured for each year.

8. State the average cost of production of each type or line of prefabricated artificial teeth that your company sold or manufactured for each year.

Respectfully submitted,

April 15, 1999


Carl Schnee

By: _________________________________
Judith M. Kinney
Assistant United States Attorney
U.S. Attorney's Office
1201 Market Street, Suite 1100
Wilmington, DE 19801
(302) 573-6277
Delaware Bar No. 3643

Mark J. Botti
William E. Berlin
Michael S. Spector
Michael D. Farber
Health Care Task Force
Antitrust Division
Washington, D.C. 20004
U.S. Department of Justice
325 7th Street, N.W., Suite 400
Washington, D.C. 20530
(202) 307-0827

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Sample Interrogatories for Lawyers in Personal Injury Cases

Written interrogatories are a useful discovery tool for plaintiffs in all types of tort cases. Written responses from a defendant can help narrow down the issues in a case. Unlike oral testimony at a deposition, written statements are much harder to wiggle out of later so interrogatories can be very effective at locking a defendant into a position on key points.

Below are example interrogatories in many different types of personal injury cases for you to use to help you prepare interrogatories in your case. We have spent a lot of time fine-tuning our interrogatory questions over the years. They are battle tested and we think they are pretty good.

sample interrogatories

Use these sample interrogatories however you like. The purpose of providing these to our colleagues is that we should all be trying to spend more time maximizing the value of our cases and less time reinventing the wheel. 

But please read the interrogatories carefully and make sure they fit your case. You need to mold them to the facts. We have reports from judges and defense lawyers of lawyers who have cut and pasted example interrogatory questions from our website in their own discovery without even changing all the names and facts.

Auto Tort Cases
  • Auto Tort Full Set of 30 Full set of all 30 interrogatories for a standard auto accident case. For tactical reasons, you may want to serve multiple sets instead of using all 30 up front.
  • First Set – Auto Tort First of 3 part set of interrogatories for a standard auto tort case. Questions in sets 1 – 3 are designed like a funnel to narrow down responses from defendants.
  • Second Set – Auto Tort Second of 3 part set of interrogatories for a standard auto tort case. Questions in this set follow up on and narrow focus of questions in the first set.
  • Third Set – Auto Tort Third and final of 3 part set of interrogatories for auto tort case. Questions in this final set attempt to follow up on the prior line of questions and lock the defendant into position.
  • Uninsured Motorist Case UIM cases involve unique issues that can be tackled very effectively through interrogatories. These are sample interrogatories on an insurer in a typical UIM case.
  • Truck Accident – Company Sample interrogatories to defendant trucking company regarding an accident caused by one of its truck drivers.
  • Truck Accident - Driver Sample interrogatories to the actual truck driver involved in a truck accident case.
Medical Malpractice Interrogatories
  • Doctor in Malpractice Case Sample of our interrogatories to a defendant doctor (and doctor’s responses) in a typical medical malpractice case.
  • Birth Injury Malpractice Case Sample of the first set of interrogatories to defendant OB/GYN in a birth injury case. Mostly informational gathering questions.
  • Nursing Home Negligence Example of initial interrogatories in a wrongful death lawsuit against a nursing home involving both malpractice and general tort allegations.
Other Tort Interrogatories
  • Product Liability Case Interrogatories to defendant designer in a product liability case involving allegedly defective boilers and HVAC system at a school.
  • Medical Device Case Sample of initial interrogatories to the manufacturer of an allegedly defective medical device.
  • Premises Liability Case First set of interrogatories to the defendant property owner in a premises liability involving an apartment complex.
  • Government Slip-and-Fall Sample interrogatories to a government entity defendant (State of Maryland) in a slip-and-fall case occurring on state property.
  • Slip and Fall Case Full set of interrogatories to defendant landowner in a typical slip and fall premises liability lawsuit.
  • Dog Bite Case Sample of initial interrogatories to a dog owner in a common dog bite liability case.
  • General Negligence Case The initial set of standard interrogatories to a defendant in a case involving claims of general negligence.
Sample Interrogatories From Defendants

Below are samples of interrogatories we have received from common defendants in tort cases, such as insurance carriers. Defendants and their attorneys tend to use the same standard form interrogatories in all cases so these interrogatory examples should give you a good idea of what to expect.

Sample Interrogatory Questions and Answers
Is There a Checklist I Can Follow to Answer Interrogatories?

This is a checklist you might want to consider in providing answers to this discovery:

  • Figure out how long you have to respond. Most states allow 30 days to respond (twenty-five in federal court under Rule 33).
  • Get a copy to your clients quickly. We like to draft some of the answers for them based on their responses to our questionnaire and other information we have, and the clients fill in the blanks. But, either way, get them out quickly. If you think you need an extension to answer, ask for it early.
  • Read them. It is trite, but you have to digest each word.
  • Figure out which questions are objectionable. Don't object just because you don't want to answer the question and try to keep the objection as narrow as possible. But if the question is overly broad, vague, privileged, or not relevant, you should object. Make sure you are not objecting to form interrogatories approved by the court.
  • Draft your answers. Write in plain English and keep in mind that these responses can be read to a jury. You know you have written a poor answer if a juror rolls their eyes when the question and answer are read in court.
  • Send the client a draft of the answers.
  • Bring them in for an appointment to go over the answers.
  • Serve a copy of the response to each party in the litigation.

There is one more really important thing to keep in mind. We draft our client's answers to save them the hassle of having to do so and because we want to word the responses in a certain way. But you have to make sure the client owns the language. Unless you go over every answer - and even interrogate them just a little bit - there is a chance you are going to get it wrong. Have ever seen someone running away from their answers to discovery at trial? It is not a pretty sight.

How Do You Draft Interrogatories in Personal Injury Cases?

The first step in drafting interrogatories is to find a sample set of interrogatories in a similar personal injury case. We have a number of samples in all different types of tort cases above.

You use sample interrogatories because there are some pieces of information you want in every single case. But you are making a mistake if you do not craft interrogatories that are specific to your case. Ask defendants the hard questions and ask them early in the case to pin them down (and to have time to file a motion to compel when they don't give complete answers).

What Is the Most Important Thing to Do After Serving Interrogatories?

The biggest mistake plaintiffs' personal injury lawyers make after serving interrogatories is not demanding complete answers. Too many lawyers spend a lot of energy drafting great questions only to fall asleep when the defendant provides inadequate answers.

This is why you file discovery early.

It allows you time to be reasonable and time to file a motion to compel long before the discovery deadline.

Who Answers Interrogatories?

Most lawyers work with their clients to get interrogatory answers and then they draft the answers for their client to sign. So both the client and the lawyer are usually involved in preparing these written responses. The objections are, of course, drafted by the attorney.

Interrogatories: How Plaintiffs Should Use Them

Interrogatories are written questions answered under oath. In most jurisdictions, parties may serve 30 written questions.

Because the number of requests is restricted without a court order or an agreement among the parties, interrogatories in a complex case should be carefully drafted to request only information that a lawyer cannot find using other discovery mechanisms.

In determining the number of questions, you can ask, subparts are counted separately. So asking an interrogatory with several questions does not help keep the number down. If an interrogatory has five related subparts, it will be counted as five interrogatories.

In 1994, Maryland Rule 2-421 was amended to allow a party to serve more than a single set of interrogatories. But the total number of requests cannot exceed thirty. Accordingly, we suggest serving more than one set. First, serve an initial set as well as later "clean-up" set so long as the total number of questions does not exceed 30. In the sample above, the first set listed assumes that all 30 interrogatories are asked at one time.

The next three sample sets are sent throughout the course of discovery. Defense counsel in a case recently refused to answer discovery because the defendant thought three sets of requests for admission and interrogatories were just too much. I do not think she has ever read Maryland Rule 2-421 or Maryland Rule 2-424.

Fortunately, we were sure that the judge that hears the motion to compel has read these rules. (Update: Yep, that is what happened!)

Another tactic that leads to quality information about defendant's case is using alternative interrogatories. These are used in conjunction with requests for admission. If a party denies a request for admission that goes to a critical component of Plaintiff's personal injury case, an alternative interrogatory asks the defendant to set forth all facts and evidence upon which the defendant intends to rely upon at trial to support the defense lawyer's denial. Attorneys hate taking positions before trial. (We do too.) So if you can pin down what the arguments will be, you will be in a much better position to structure your case effectively.

This rule does not direct how the questions are to be asked. It can be either in the form of a question (usually contention interrogatories), or they can direct the answering party to supply accurate information that is described.

Insurance defense counsel often refuses to answer discovery. They are just looking for creative ways to circumvent answering discovery. Why do they do it? Few plaintiffs' attorneys hold their feet to the fire and make them answer in the face of silly objections.

Frivolous objections come in many shapes and sizes. The most classic objection is that the interrogatory asked is objectionable under Maryland law because it is "vague, burdensome, overly broad, and not reasonably calculated to lead to admissible evidence." Many use this objection to the simplest of questions. As suggested above, you will often get this response even when you using template questions employed by the court.

They also object because a particular word is not defined (no matter what the word is, right down to question what the definition of "is" is). Another favorite objection is that the plaintiff bears the burden, so no answer is required, an objection that is beyond silly.

No matter what the objection, the key is to object quickly and press the defendant with a motion to compel if necessary. The process adds layers of time, expense and tedious effort because a motion must be drafted and typically the judge will require the lawyers to attend a hearing on the motion. But the pursuit is worth getting proper and complete answers.

Think About How You Will Use Interrogatory Responses at Trial

The best advice for propounding, answering and following up on interrogatory answers is the one thing that few attorneys do: put thought into them as to exactly how you are going to use them at trial. We get so much advice as to what we should do. As a result, we make a lot of diving impossible catches but miss too many fly balls. Just think about what you are trying to prove at trial and explore those issues. Think about the questions that box in the defendant (in one direction or the other). Think about the hard questions that you would like to get answers to read to a jury. Think about the case individually. Then draft your discovery and demand answers that fairly and honestly answer the questions. Focusing just on this is better than reading a thousand different articles on developing discovery.

More Discovery Resources to Put Your Case Together Related Topics

It's just too early to thank, you have no idea who I am and what I'm going to do with you. I tried to include her logic a bit. And cool the ardor. And I have no idea who you are. Although I suspect that she herself does not know this.

Defendant to sample interrogatories

But there was such an emptiness in my soul, the cats were scratching, I thought that you completely abandoned me, and I have nowhere to return. I washed and lay down in his pastel in one nightie. I was shaking like crazy cold. But he did not bother me, I myself asked for a relaxing massage.

What are defendants Answers to Interrogatories

This biographical piece of paper crossed out from the tragic fate of the madman Surganov with a detailed description of his childhood and youth. In the same way, compiled according to the reporting by the precinct of the village of Molodezhny, where Andrei Alexandrovich Surganov lived with his parents and other.

Relatives from his place of residence and the investigators of the city of Divnogorsk, who were then conducting those cases on those tragic cases, almost thirty years ago from his forgotten youthful life.

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