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Failure to Answer Interrogatories. 1. A failure to fully answer interrogatories shall be directed to the Courts attention by filing a Motion for Enforcement of Discovery pursuant to Supreme Court Rule 61.01. Compliance with the Golden Rule, as set forth in Circuit Court Rule 33.5, must accompany such motion.
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). Failure to include this verification has the same effect as not responding at all.
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.
There is no form for your answer, but you typically have to respond in a specified format, using paper with numbers down the left-hand side, with your name and address at the top left, the name of the court and of the case, and the case number.
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.
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List of Sample Objections Plaintiff objects to this interrogatory as vague, ambiguous, argumentative, overbroad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. Plaintiff objects to this interrogatory because it calls for the plaintiff to make a legal conclusion.
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.

letter of objection sample