Interrogatories in Civil Litigation: A Comprehensive Guide to Objecting and Responding

62 questions on interrogatories in civil litigation, answered and cited by the UpLaw editorial team.

• Are boilerplate general objections still permitted?
• Can an individual verify interrogatory answers on information and belief?
• Can an interrogatory ask for a legal conclusion?
• Can I get leave to serve more than twenty-five interrogatories?
• Can I object that a contention interrogatory is premature?
• Can I refuse to answer an entire interrogatory because part of it is objectionable?
• Can I refuse to answer an interrogatory because I discussed the topic with my lawyer?
• Can I serve interrogatories on a nonparty witness?
• Can I use an interrogatory to get documents from the other side?
• Can you give an example of subparts that count as one interrogatory versus two?
• Does an interrogatory verification need to be notarized?
• Does proportionality mean discovery is limited by the dollar amount at stake?
• Do I have to update an interrogatory answer after I serve it?
• Do subparts count against the twenty-five-interrogatory limit?
• How aggressive should I be in written discovery?
• How can a responding party get protection from oppressive interrogatories?
• How does a corporation verify interrogatory answers?
• How does subpart counting cut both ways for drafters and responders?
• How do I draft an interrogatory that is hard to evade?
• How do I frame a burden objection that will actually hold up?
• How do I frame an overbreadth objection?
• How do I frame a relevance objection to an interrogatory?
• How do I object that an interrogatory is vague or ambiguous?
• How do I state a discovery objection with specificity?
• How do I structure a motion to compel interrogatory answers?
• How many interrogatories can I serve?
• How should I use interrogatories offensively?
• Is it a valid objection that the asking party already knows the answer?
• Is "reasonably calculated to lead to the discovery of admissible evidence" still the standard?
• Should I serve all twenty-five interrogatories at once?
• What are interrogatories actually good at?
• What are the essential takeaways on interrogatory practice?
• What are the proportionality factors under Rule 26(b)(1)?
• What belongs in the instructions section of an interrogatory set?
• What does a well-drafted interrogatory answer look like?
• What does it cost to lose a motion to compel?
• What does it mean to answer an interrogatory "fully"?
• What does Rule 26(g) certify when a lawyer signs a discovery response?
• What do I say when I genuinely cannot find the answer to an interrogatory?
• What happens if I fail to supplement an interrogatory answer?
• What happens if I miss the deadline to object to interrogatories?
• What is a contention interrogatory?
• What is a disciplined workflow for responding to a set of interrogatories?
• What is an interrogatory in civil litigation?
• What is the right defensive posture when answering interrogatories?
• What is the Rule 33(d) business-records option?
• What is the scope of a permissible interrogatory?
• What must a party do to invoke Rule 33(d) properly?
• What must I do before filing a motion to compel interrogatory answers?
• What sanctions follow disobeying an order to answer interrogatories?
• What should I not waste an interrogatory on?
• What should the definitions section of an interrogatory set contain?
• When can interrogatories first be served?
• When is a deposition better than an interrogatory?
• When is the Rule 33(d) option unavailable?
• When should contention interrogatories be served?
• When should I use a request for admission instead of an interrogatory?
• Which rules govern interrogatory practice besides Rule 33?
• Who bears the burden on a proportionality objection?
• Who must sign and verify interrogatory answers?
• Why are interrogatories valuable even though they lack the drama of a deposition?
• Why do local rules matter so much in interrogatory practice?