Interrogatories and Requests for Production - Personal Injury 2025

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If the opposing side does not respond to your form interrogatories, special interrogatories, or request for production, you may file a motion seeking an order compelling the opposing party to respond.
Interrogatories are written questions sent by one party to another, which the responding party must answer under penalty of perjury. Interrogatories allow the parties to ask who, what, when, where and why questions, making them a good method for obtaining new information.
The request is vague, ambiguous, or unintelligible. Sometimes, it is impossible to determine what the propounding party is asking you to produce. In these situations, you may object to the request on the grounds that it is vague, ambiguous, or unintelligible.
Ask for a court order If the other person does not respond, or their response is still incomplete, you can ask the court to order them to respond. You have 45 days from the service of the most recent responses to ask the court to make an order requiring an answer.
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.

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However, you can object to interrogatories that call for legal conclusions. You can also object to questions if they are not at all related to the court case. To object, you need to write out the reasons for the objection instead of answering the question.
If a party or partys officer, director, or managing agent fails to obey a discovery order, the court may issue further orders. A court must also order a disobedient party, the advising attorney, or both to pay expenses resulting from the failure to reply.
Interrogatories are lists of questions sent to the other party that s/he must respond to in writing. You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.

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