Introduction

The word interrogatory comes from the same root word as interrogative.  An interrogative sentence in English grammar is a sentence that involves a question.  The word interrogatory is just the lawyer word for a written out question.  

Interrogatories are just a set of questions typically posed to an adverse party in litigation.  Examples would include, "state the name, address, and telephone number of each person that witnessed the incident," and "state the amount that you admit you owe and describe and explain in detail your basis for calculating that amount."  There are standard "form" interrogatories that most lawyers can spit out of their computers and in most cases when interrogatories are sent to an opposing party some of the questions posed will be dovetailed to the specific facts of the case.  

Form

The Form-Interrogatories linked here are a sample of the type and style of interrogatories that are typically sent in litigation.  

How to Respond to Interrogatories

If you are in litigation it is quite likely that you will receive a set of interrogatories to which you must respond.  The first thing to know about interrogatory responses is that your responses will be verified.  That means that a Verification will be attached to the responses.  A Verification is really just an affidavit in which the responding party swears under oath that the responses to the interrogatories are true.  This distinguishes your responses to interrogatories from responses to requests for production of documents and requests for admissions, neither of which are under oath.  

Responding to interrogatories typically means nothing more or less than reading the question and writing out an answer.  A typical problem that arises is how much time, effort, and research to put into responding to a particular interrogatory.  The interrogatory may ask you to identify all of the physicians you have seen in the last 10 years, and it may ask for their addresses, telephone numbers, charges, diagnoses, and treatments.  You may have seen just 3 doctors in the last 10 years or 30.  You may be the type of person that keeps immaculate records or none at all.  It may be that you can't recall even the doctors names but you know that if you obtain records from your past 2 insurers, then locate the doctors, then request and review records, you can provide all of the information sought by an interrogatory.  Exactly how much detail and how much work to do in responding to an interrogatory should be the subject of some discussion between you and counsel.  Suffice to say here, if you can reach around and pull a file out of the drawer and provide a name, address, telephone number, and some treatment information you ought to do so.  On the other hand if you have to go to some superhuman effort and become an investigator as in the example of calling your insurer this is probably going to far and is not required of you in responding to an interrogatory.  

Sample Responses

Click this link to view Sample Responses to interrogatories.  

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Last modified: December 05, 2006