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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.
Have a strategy. Adjust the scope of your requests to the questions at issue. Send clear requests. Always consider how your client would be prepared to respond to similar requests. Make your objections clear and specific.
Personal/Corporate information of opposing party. Identifying information of witnesses. Contact information & background of expert witnesses. Insurance information.
(2) Answers to interrogatories are admissible at trial against the answering party. Thus, they serve to prevent equivocation by the other party and tend to safeguard against surprise.
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.
A: Assuming that I draft about 30 - 40 questions per set, and assuming that I can re-use some of my special interrogatories from other past cases, then maybe 2 - 3 hours of my time to prepare a set of special interrogatories. Then another 1 - 2 hours afterward to review and discuss their responses with you.
So, can you refuse to answer interrogatories? The answer is, no, you may not.That answer must either permit inspection of the requested information or object to the production of the information for a specific reason.
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.