This is a sample set of interrogatories which are served on a defendant insurance company in an insurance fraud matter.
Alabama Insurance Fraud - Interrogatories to Defendant Agent
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FAQ
Interrogatories Interrogatories are written questions that are sent by one party to another. Generally speaking, the party who receives these questions has 30 days to answer them.If the other party fails to respond on time, within 30 days, then the questions are deemed admitted.
The plaintiff must respond by the deadline. There are different ways to make sure you get each kind of discovery if the plaintiff does not give it to you by the deadline. If the plaintiff does not respond to the court order, then you can file a Motion to Dismiss and you may win your case.
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.
You must answer each interrogatory separately and fully in writing under oath, unless you object to it. You must explain why you object. You must sign your answers and objections.
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.
So, can you refuse to answer interrogatories? The answer is, no, you may not. You must answer a Rule 33 interrogatory within 30 days of being served with it. That answer must either permit inspection of the requested information or object to the production of the information for a specific reason.
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.
Responding to Form InterrogatoriesAnswer each question, being careful to answer each subpart, if one exists. Read the question carefully, and answer only what it asks. You may attach exhibits, if necessary. The response must be verified, meaning you must swear that the responses given are true.
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 . . .