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Personal/Corporate information of opposing party. Identifying information of witnesses. Contact information & background of expert witnesses. Insurance information.
In law, interrogatories (also known as requests for further information) are a formal set of written questions propounded by one litigant and required to be answered by an adversary in order to clarify matters of fact and help to determine in advance what facts will be presented at any trial in the case.
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.
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.
Form rogs aren't objection-proof, though much of the time, the objections are nonsensical. The parties have to meet and confer to resolve a discovery dispute anyway.
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.
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.
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.