Arkansas Sample Letter for Plaintiff's Motion to Compel Answers to Plaintiff's Second Set of Interrogatories
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How to fill out Sample Letter For Plaintiff's Motion To Compel Answers To Plaintiff's Second Set Of Interrogatories?
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If the court grants leave or the party consents, you can deliver interrogatories to any party in the action and they must be replied to within 21 days of delivery. Answers to interrogatories are delivered in the form of an affidavit, so the party answering the questions swears to the truth of the answers.
There should be only three goals in answering interrogatories: accurate, complete, minimal. Accuracy is important because, pursuant to Rule 33(a), SCRCP, these answers are verified by the client under oath and, under Rule 801(d)(2), SCRE, are admissions of a party opponent.
A motion to compel further responses to interrogatories is a prime example. (This is where you've received responses to interrogatories, believe them to be incomplete, and you want the court to order the responding party to provide further responses.)
If you are unable to answer an interrogatory because it is too vague, ambiguous, or somehow objectionable, you can state an objection and the reason for your objection. You must then answer to the extent the interrogatory is not objectionable.
Since the questions are written, the witness may have more time to think and craft answers, rather than providing more candid answers during discovery. There is also no chance for back and forth questioning in an interrogatory, unless a subsequent deposition is scheduled.
(b) Good Faith Efforts to Confer Before a party files a motion to compel a response to discovery, the party must make a good faith effort to confer with the person or party allegedly failing to properly respond to a request for discovery in an effort to secure information or material without action by the ALJ.
