Deck 11: Interrogatories

Question 1

Who must sign the deponent's answers to interrogatories?

A) the deponent.
B) the deponent's lawyer.
C) the paralegal who assisted in preparing the answers.
D) (a) and (b) only.
E) all of the above.

Answer 1

D

Question 2

Why are interrogatories used to determine whether parties are insured?

Answer 2

Discovery of insurance is allowed because it may have a significant effect on the parties' willingness or ability to settle their dispute. The most efficient means of obtaining insurance information is through written inter- rogatories.

Question 3

DEFINE
party's work product

Answer 3

A party's work product is similar to attorney's work product. It is the product of a party's efforts to prepare for trial or the product of a party's efforts in preparation for litigation. Rule 26 protects from discovery a party's work product except in exceptional circumstances. Many lawyers use the term "attorney's work product" interchangeably with "party's work product."

Question 4

If a deponent does not have actual personal knowledge of a matter addressed in an interrogatory, the deponent may answer the interrogatory by qualifying his or her answer by stating the answer is provided upon and .

Question 5

What advantages are there in using interrogatories rather than taking the deponent's deposition?

Question 6

If the deponent wrongfully withholds or conceals information by giving incomplete or misleading answers, the deponent is subject to
.

Question 7

State three guidelines for drafting interrogatories.

Question 8

Interrogatories are particularly valuable for obtaining what kind of information?

Question 9

Can an interrogatory impose a duty upon a deponent to obtain information he or she does not know or have?

Question 10

How may the deponent try to obtain additional time in which to answer a set of interrogatories?

Question 11

If the deponent does not have the information with which to answer an inter- rogatory, what must the deponent do to comply with the spirit of the discovery rules?

Question 12

Under what circumstances may interrogatories be served upon a nonparty?

Question 13

Generally, consultation with an expert who is not selected to testify is consid- ered part of the attorney's , and, therefore, not discoverable.

Question 14

The answers to interrogatories may be used at trial in a of the deponent.

Question 15

How many sets of interrogatories may any one party serve upon another party?

Question 16

When must answers to interrogatories be supplemented?

Question 17

What should the defendant do if, at trial, the plaintiff were to attempt to prove that the defendant was negligent in some respect not described in the plaintiff's answer to interrogatories?

Question 18

Interrogatories are the only form of discovery that may be used to obtain information about what matters or subjects in many state courts?

Question 19

The content of the answers to interrogatories must be based upon the infor- mation available to the:

A) party.
B) the party's lawyer.
C) the party's employees and agents.
D) (a) and (b) only.
E) all of the above.

Question 20

A of interrogatories is a group of interrogatories that a party currently wants answered.

Question 21

What should the deponent do if he or she believes that the proponent's inter- rogatories are excessively burdensome or constitute harassment?

Question 22

As a matter of preferred form, what should be the first number of the second set of interrogatories?

Question 23

What should a deponent do if he or she cannot respond to certain interroga- tories until he or she has all the evidence available to consider?

Question 24

May a party inform the jury that the opponent was subject to Rule 37 sanctions for abusing discovery procedures?

Question 25

What is one of the important differences between Rule 33 answers to inter- rogatories and Rule 36 responses to requests for admissions?

Question 26

How should the deponent respond to an interrogatory if the information called for is unknown to the deponent and is equally available to the proponent?

Question 27

May a party refuse to answer interrogatories on the grounds that the other party is late in answering interrogatories?

Question 28

What may the deponent do if the proponent's set of interrogatories exceeds the number limit established by state or federal rules?

Question 29

What is the customary procedure for obtaining a court ordered extension of time to respond to interrogatories?

Question 30

What may a deponent do if a proponent serves an interrogatory about the contents of various business records and the deponent believes the amount of
time and effort required to examine the records to obtain the information is very substantial and unreasonably burdensome?