Discovery and evidence

Interrogatories

Interrogatories are written questions one party sends another, which must be answered in writing and under oath.

The federal default is twenty-five questions, counting subparts, unless the court or the parties agree to more. Answers are due in thirty days, and they bind the party: an answer that later turns out to be wrong must be supplemented.

They are best at facts a company can look up, such as identifying witnesses, custodians, insurance policies, and the basis for a specific defense. They are poor at anything requiring nuance, because the answers are drafted by lawyers.

Answers are also useful later as admissions. Because they are sworn and binding on the party, a shifting position between an interrogatory answer and trial testimony is exactly the material lawyers use for impeachment.

How it appears on a docket

Discovery requests are usually served, not filed, so the docket shows only disputes: MOTION to Compel Responses to Plaintiff's First Set of Interrogatories.

Governing rule

Fed. R. Civ. P. 33

Related terms

  • Request for ProductionA request for production is a written demand that another party hand over specified documents, electronic files, or things for inspection.
  • Motion to CompelA motion to compel asks the judge to order another party to answer discovery or produce documents it has withheld.

More on discovery and evidence

See this term in a real case

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