Type 1: New York Sample Letter for Review of Answers and Objections to Plaintiff's 2nd Set of Interrogatories — General Dear [Recipient's Name], I hope this letter finds you well. I am writing to bring to your attention the recent submission of answers and objections to the plaintiff's second set of interrogatories in the ongoing litigation between [Defendant's Name] and [Plaintiff's Name]. Upon reviewing the responses provided, it is evident that there are areas where further clarification or supplementation is necessary. This letter aims to outline our concerns and request the required information to ensure a fair and transparent resolution to this case. 1. Form and Content Transgressions: Firstly, we have identified certain instances where the provided responses fail to comply with the prescribed format or do not sufficiently address the interrogatory posed. We kindly request that you review these discrepancies and promptly provide amended answers that align with the requirements outlined in the New York Civil Procedure Rules. 2. Unsupported Objections: Secondly, we have noticed various objections put forth by your client that lack a sufficient legal or factual basis. It is our contention that these objections are merely evasive tactics aimed at avoiding potential disclosure of key information. We urge you to reconsider these objections and provide appropriate responses instead. 3. Privilege Assertions: We have also noted several instances where your client has asserted privileges over certain information sought in the interrogatories. While we respect that justified privileges may exist, it is necessary for you to substantiate the claimed privileges by providing a privilege log or any supporting documentation. Failure to do so will impair our ability to evaluate the legitimacy of these assertions and may necessitate further legal action. 4. Incomplete or Partial Answers: Lastly, there are portions of the responses that appear to be incomplete or partially provided. It is essential that you review these sections and provide detailed and comprehensive answers to each interrogatory. Ambiguity or vagueness in the responses may lead to confusion and impede the progress of this case. In light of the aforementioned concerns, we hereby request that you revisit the provided answers and objections, addressing the deficiencies pointed out. We expect the supplemented responses to be accurate, complete, and in accordance with the New York Civil Procedure Rules governing interrogatories. We kindly request a prompt response to this letter within [reasonable timeframe]. Failure to provide satisfactory responses may compel us to seek judicial intervention or take any other appropriate legal action available to us. Thank you for your attention to this matter. We look forward to receiving your revised responses. Sincerely, [Your Name] [Your Law Firm] [Contact Information] Type 2: New York Sample Letter for Review of Answers and Objections to Plaintiff's 2nd Set of Interrogatories — Breach of Contract Dear [Recipient's Name], I hope this letter finds you well. I am writing to address the recent submission of answers and objections to the plaintiff's second set of interrogatories in the breach of contract case between our client, [Defendant's Name], and [Plaintiff's Name]. Having carefully reviewed the responses provided, we have identified several areas of concern that prompt us to request further clarification and supplementation. This letter outlines our reservations and seeks the necessary information to facilitate a fair resolution of this dispute. 1. Inadequate Responses to Material Facts: Upon reviewing the answers to interrogatories, it has become apparent that certain crucial information requested by our client has not been adequately addressed in the responses provided. We kindly request that you reexamine these specific interrogatories and furnish detailed, accurate, and complete answers to ensure a comprehensive understanding of the facts surrounding this breach of contract claim. 2. Unjustified Objections: It has come to our attention that your client has made multiple objections without providing a substantiated legal or factual basis. We contend that such objections are purely evasive and impede the discovery process. We urge you to reconsider these objections and provide responsive answers, as required by the New York Civil Procedure Rules. 3. Non-Disclosure of Key Evidence: Our review of the responses reveals instances where our client believes pertinent evidence has been omitted or withheld. It is crucial that you review the completeness of the submitted responses and promptly provide any outstanding documents, records, or other evidence requested, which are material to this breach of contract matter. 4. Privilege Assertion: We acknowledge your client's assertion of privilege over certain information requested in the interrogatories. However, it is imperative that you substantiate these claimed privileges by providing a privilege log or any supporting documentation. Your cooperation in this regard is essential for a thorough evaluation of the legitimacy of these assertions. We kindly request your immediate attention in revisiting the provided responses and objections, addressing the aforementioned deficiencies. It is crucial for your revised responses to adhere to the New York Civil Procedure Rules governing interrogatories, being complete, precise, and accurate. We expect a timely response to this letter within [reasonable timeframe]. The failure to provide satisfactory responses may leave us with no choice but to seek judicial intervention or take any other appropriate legal action available to us. Thank you for your cooperation. We eagerly await your revised responses. Sincerely, [Your Name] [Your Law Firm] [Contact Information]
New York Sample Letter for Review of Answer's and Objections to Plaintiff's 2nd Set of Interrogatories
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FAQ
Some of the valid grounds for objecting to interrogatories are: Irrelevant questions or questions outside the scope of permissible discovery. The information sought for is privileged (protected under the attorney client privilege doctrine or the like)
If the question contains several parts, you may break your answer into parts as well. It is also possible that you might object to the question. To raise an objection, you write ?Responding party objects on the grounds? followed by why you object.
If you are unable to answer a specific question because you don't know or don't have access to the appropriate information, you must indicate the reasons. You may refer to a previous response when responding to an interrogatory providing the previous response sufficiently answers the later interrogatory.
Unless your written response includes only objections without any factual assertions, it must be verified. This means it must include a statement under the penalty of perjury that your response is true and correct. (CCP § 2031.250).
If you do not answer the questions by the deadline, which is usually about a month, the other side could ask the judge to order you to respond to the interrogatories. If you miss the second deadline, the judge could impose a fine against you or strike your pleadings.
The plaintiff must give you responses to the request for interrogatories within 45 days of when you mailed the request. If they do not give you a response you can send a final request to the plaintiff. In the final request tell the plaintiff they have another 30 days to give you answers to your interrogatory requests.
If the question contains several parts, you may break your answer into parts as well. It is also possible that you might object to the question. To raise an objection, you write ?Responding party objects on the grounds? followed by why you object.
You can object to an interrogatory if the information sought is known by the requesting party or available to both parties equally. For example, you should raise this objection if the answers are publicly available or in a third-party's custody or control.
