Discovery Interrogatories from Defendant to Plaintiff with Production Requests - Pennsylvania 2025

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Under the Pennsylvania statute of limitations, a plaintiff must bring a medical negligence claim within two years after an injury occurs. There is an exception, deemed the discovery rule, which allows extra time to file the claim if the plaintiff was unaware of the injury until after two years had passed.
Rule 4005 - Written Interrogatories to a Party (a) Subject to the limitations provided by Rule 4011, any party may serve upon any other party written interrogatories to be answered by the party served or, if the party served is a public or private corporation or similar entity or a partnership or association, by any
Unless leave of court is obtained, interrogatories may not be served prior to the meeting of the parties under Rule 26(f).
Unlike interrogatories Requests to Produce are not limited in number. Upon receipt from the opposing party your business lawyer working with you will assess whether any requests are objectionable and what should be produced. These production requests are regularly used in lawsuits.
Complete Your Responses to the Interrogatories You must respond to each request individually. You do not need to repeat the text of the question, but your responses must be in the same order as the requests, and each response should be labeled with the same number or letter as the request.
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Interrogatories shall be prepared in such fashion that sufficient space is provided immediately after each interrogatory or subsection thereof for insertion of the answer or objection. Rule 440 requires the party serving interrogatories upon any other party to serve a copy upon every party to the action.
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.

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