Interrogatories

Interrogatories

Interrogatories

Interrogatories are written questions directed to a party, answered under oath by the party rather than by counsel. Federal practice presumptively limits them to twenty-five including discrete subparts.

Answers may be supplemented, and a party may in some circumstances produce business records in lieu of answering where the burden of deriving the answer is substantially the same for both sides.

Alternative Names:

ROGs, Written Interrogatories

Why it Matters?

Interrogatories are best used for information a party must compile rather than narrative explanation: identification of witnesses, computation of damages, insurance information, and the factual basis for specific contentions. Using them for open-ended narrative wastes limited questions and produces lawyer-drafted answers of little value. Contention interrogatories timed near the close of discovery are the exception, since they force a party to commit to a theory.

Frequently asked questions

How many interrogatories are permitted?

How many interrogatories are permitted?

Twenty-five including discrete subparts in federal court, unless the parties stipulate or the court orders otherwise. State limits differ.

Who signs interrogatory answers?

Who signs interrogatory answers?

The responding party signs under oath, and counsel signs as to objections. Answers verified only by counsel are subject to challenge.