Response to Interrogatories – Examples

It can be really daunting to receive a list of interrogatories to answer. Below is a list of sample replies that you can use as a baseline to answer the questions that you might have been asked.

WARNING: Before you send these responses to interrogatories, you need to check your local court rules. These may have to be signed and notarized before mailing it back to the plaintiff.


Are they asking you for the last check number written to this account?

Objection:
Interrogatory No. 6 is objected by Defendant on the grounds that it is over broad and unduly burdensome to the extent it seeks documents or records that are that are not within the current knowledge, possession, custody or control of Defendant. Without waiving his objection, Defendant to the best of his knowledge has never written a check to the order of the original creditor or to the order of Plaintiff.


Are they asking you to list dates and payments made that you claim were made to the account?

Objection:
Interrogatory No. 7 is objected by Defendant on the grounds that it is unreasonably cumulative or duplicative, overly broad and unduly burdensome to the extent it seeks documents or records that are that are not within the current knowledge, possession, custody or control of Defendant. Without waiving his objection, Defendant states that he has never claimed he made any payments by check, money order, banks official check or any other means, therefore cannot list any.


Are they asking you to provide information about witnesses you may call to the trial?

Objection:
Interrogatory No. 12 is objected to the extent that it is seeking information that is premature, given that the parties are in the midst of discovery and pertinent documents have not yet been produced by Plaintiff. Defendant cannot possibly answer this interrogatory when he has not seen Plaintiff’s answers to his discovery. Without waiving his objection, Defendant at this time has no witnesses, but reserves the right to call witnesses, if need be, once Plaintiff answers their discovery given by Defendant.


Are they asking you for information about exhibits you will use at trial?

Objection:
Interrogatory No. 13 is objected to as it is once again requesting information that it is premature given that the parties are in the midst of discovery and pertinent documents have not yet been produced by Plaintiff.


Are they asking you for factual basis of each defense you now assert?

Objection:
Interrogatory No. 15 is objected to by Defendant on the grounds that it is seeking information that is premature given that the parties are in the midst of discovery and pertinent documents have not yet been produced by Plaintiff.

Without waiving his objection, Defendant upon completion of discovery with Plaintiff, will most definitely have defenses in this action, and will provide such defenses to Plaintiff if asked through discovery. Defendant reserves the right to update this answer to this interrogatory at a later time when that decision is made.



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