Discovery

Written Discovery

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?

Who signs interrogatory answers?