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Commonly Asked Questions about Interrogatories in Civil Cases

Rule 33 (b), Federal Rules of Civil Procedure , requires the respondent to answer an interrogatory separately and fully in writing and under oath, unless the respondent objects, in which event the party objecting shall state with specificity the reasons for objection and shall answer to the extent the interrogatory is
Whether to admit interrogatory answers is within the discretion of the trial court, just as with any other evidence, and a trial courts refusal to admit such evidence will only be reversed upon a showing of manifest abuse of that discretion.
You need to be clear in your objections or risk waving them. Federal Rule 33(b)(4) emphasizes that the grounds for objecting to an interrogatory must be stated with specificity. Any ground not stated in a timely objection is waived unless the court, for good cause, excuses the failure. Cheat Sheet for Interrogatory and Discovery Objections millerandzois.com sample-interrogatories millerandzois.com sample-interrogatories
Usually, lawyers use interrogatories to obtain detailed information about persons, corporations, facts, witnesses, and identity and locations of records and documents. Court rules usually limit the number of questions included in an interrogatory.
Interrogatory answers, in order to be used as substantive evidence at trial, must be introduced into evidence as part of the record.
The person who makes the answers must sign them, and the attorney who objects must sign any objections. (c) Use. An answer to an interrogatory may be used to the extent allowed by the Federal Rules of Evidence.
Interrogatories are often preferable to depositions for identi- fying such things as witnesses, documents, the dates and sub- stance of transactions and conversations,3 since a deponent may easily forget or overlook relevant information when an- swering such questions.
You have to respond to interrogatories in writing to the best of your ability. If you do not answer an interrogatory question, and then the other side learns that you did in fact know the answer, it could have a negative impact on your case at trial.