Interrogatories

What are interrogatories?

Interrogatories are written questions one party sends another during discovery, to be answered in writing and under oath.

Court rules typically limit the number that may be served, which forces both sides to focus on what genuinely matters rather than asking everything imaginable.

Answers are typically drafted with attorney assistance, though you must review and confirm them, since you are certifying their accuracy under penalty of perjury.

They are usually the first substantive discovery device used in a case, arriving before depositions and setting up much of what follows.

What kinds of questions are typical?

Standard sets cover recurring categories across most injury cases.

• Your account of how the incident occurred
• Every injury and body part affected
• Every healthcare provider who treated you, past and present
• Prior accidents, injuries and claims
• Employment history and lost income
• Identification of witnesses and documents you intend to rely on

Why do they matter so much?

Because your answers are treated as sworn statements, exactly like deposition testimony. Later inconsistency can be used to challenge your credibility.

They also frame the deposition that follows. Defense counsel reviews your answers beforehand and builds questions around anything unclear or incomplete.

Incomplete or evasive answers frequently prompt a motion to compel, which adds delay and cost without changing what you will eventually need to disclose.

Vague or overly general answers also invite more aggressive deposition questioning, since counsel probes precisely where the written answer left room for doubt.

What should you keep in mind while answering?

Completeness matters more than brevity. Omitting a prior injury or a treating provider because it seems irrelevant tends to surface later and looks far worse than disclosing it upfront.

Review your medical records before answering questions about treatment history, since memory alone is an unreliable source for dates and providers spanning years.

Answers can generally be supplemented if new information arises, so an honest gap discovered later is far less damaging than information withheld.

Common questions

Do I have to answer every question?

Objections can be raised for improper or overly broad questions, but most substantive questions about your claim must be answered.

What if I do not remember something exactly?

Answer to the best of your recollection and say so where memory is uncertain. Reviewing your own records beforehand reduces how often this arises.

Can my answers be used against me at trial?

Yes. They are sworn statements and can be used to highlight any inconsistency with later testimony.