Interrogatories

AuthorAshley Lipson
Pages245-554
INTERROGATORIES
6-1
Like a long range missile
an interrogatory does its damage
from a safe distance away.
CHAPTER 6
INTERROGATORIES
§6.10 BASIC TRAINING AND STRATEGY
§6.10(a) Interrogatory Restrictions
§6.11 Anatomy of a Single Interrogatory
§6.12 The Interrogatory’s Advantages Preliminary General Order
§6.13 The Interrogatory’s Disadvantages
§6.14 Three Critical Considerations
§6.20 TIPS FOR TIMING YOUR ATTACK
§6.30 INFORMATION TO TARGET AND CAPTURE
§6.31 Identity and Capacity of Responding Person
§6.32 Identity and Location of Witnesses and Parties
§6.33 Identity and Location of Evidence
§6.34 Elements of Your Claim or Defense
§6.35 The Enemy’s Pleading
§6.36 Non-Evidentiary Disclosures
§6.37 Enemy Expert Information
§6.40 THE RULES THAT YOU NEED
§6.41 Federal Rules Pertaining to Interrogatories
§6.42 The States’ Rules
§6.50 CONSTRUCTING YOUR INTERROGATORIES
§6.51 Preliminary Considerations
§6.52 Rules of Construction
§6.60 RESPONDING TO INTERROGATORIES
§6.61 Provide Answers
§6.62 State That Answers are Subject to Pending Discovery
§6.63 State a Lack of Information or Knowledge
§6.64 Elect To Produce Business Records
§6.65 Object to Questions
§6.66 Seek a Protective Order
INTERROGATORIES
Guerrilla Discovery 6-2
§6.70 ENFORCING THE REQUESTS
§6.71 No Responses by Opposition
§6.72 Evasive or Improper Responses by Opposition
§6.80 THE FORMS THAT YOU NEED
Form 6.1 Plaintiff ’s Interrogatories to Defendant
Form 6.2 Defendant’s Interrogatories to Plaintiff
Form 6.3 Interrogatories—Contract/Accounting Related Actions
Form 6.4 Interrogatories—Tort Related Actions
Form 6.5 Interrogatories—Defamation
Form 6.6 Interrogatories—Fraud
Form 6.7 Interrogatories—Vehicular Negligence
Form 6.7(a) Interrogatories—Vehicle/Bicycle Accident
Form 6.8 Interrogatories—Malpractice
Form 6.9 Interrogatories—Premises Liability
Form 6.9(a) Interrogatories—Workplace Liability
Form 6.9(b) Interrogatories—Sexual Harassment in the Workplace
Form 6.10 Interrogatories—Product Liability
Form 6.11 Interrogatories—Domestic Relations
Form 6.12 Interrogatories—Testamentary Challenges
Form 6.13 Motion for Partial Summary Judgment By Plaintiff
(Where Local Rules Restrict Subject Matter of Interrogatories)
Form 6.14 Answers to Interrogatories
Form 6.15 Motion to Permit Service of Additional Interrogatories
Form 6.16 Answers to Requesting Party’s First Set of Interrogatories
Form 6.17 Objections to the Requesting Party’s First Set of Interrogatories
Form 6.18 Responding Party’s Exercise of Option to Produce Business Records in Response to Requesting
Party’s First Set of Interrogatories
Form 6.19 Enforcement for Interrogatories—Letters
Form 6.20 Motion to Compel Answers to Interrogatories
Form 6.21 Motion to Compel Supplemental Answers to Interrogatories
Form 6.22 Motion to Compel Additional Answers to Interrogatories
Form 6.23 Motion for Contempt Citation, Sanctions and Dispositive Relief
Form 6.24 Answer to Motion to Compel Discovery
Form 6.25 Agreement for Extension—Letter
Form 6.26 Response to Motion to Compel Answers to Interrogatories
Form 6.27 Response to Motion for Sanctions and Dispositive Relief
§6.90 JUDICIALLY APPROVED FORM INTERROGATORIES
Form 6.101 California Approved Judicial Council Form Interrogatories General
Form 6.102 California Approved Judicial Council Form Interrogatories Employment Law
Form 6.103 California Approved Judicial Council Form Interrogatories
Unlawful Detainer (Landlord Tenant)
Form 6.104 California Approved Judicial Counsel Form Interrogatories Limited Civil
Form 6.105 California Approved Judicial Counsel Form Interrogatories Construction
Form 6.201 Florida Standard Interrogatories—Form 1 Negligence to Plaintiff
Form 6.202 Florida Standard Interrogatories—Form 2 Negligence to Defendant
Form 6.203 Florida Standard Interrogatories—Form 3 Med. Malpractice to Plaintiff
Form 6.204 Florida Standard Interrogatories—Form 4 Med. Malpractice to Defendant
Form 6.205 Florida Standard Interrogatories—Form 5 Auto Negligence to Plaintiff
Form 6.206 Florida Standard Interrogatories—Form 6 Auto Negligence to Defendant
Form 6.301 New Jersey Uniform Interrogatories—Form A Personal Injury to Plaintiff
Form 6.302 New Jersey Uniform Interrogatories—Form A(1) Med. Malpractice to Plaintiff
Form 6.303 New Jersey Uniform Interrogatories—Form A(2) Product Liability to Plaintiff
INTERROGATORIES
6-3 Interrogatories
Form 6.304 New Jersey Uniform Interrogatories—Form B Auto Damage to Plaintiff
Form 6.305 New Jersey Uniform Interrogatories—Form C Personal Injury to Defendant
Form 6.306 New Jersey Uniform Interrogatories—Form C(1) Auto Negligence to Defendant
Form 6.307 New Jersey Uniform Interrogatories—Form C(2) Slip and Fall to Defendant
Form 6.308 New Jersey Uniform Interrogatories—Form C(3) Med. Malpractice to Defendant
Form 6.309 New Jersey Uniform Interrogatories—Form C(4) Product Liability to Defendant
Form 6.310 New Jersey Uniform Interrogatories—Form D Property Damage to Defendant
Form 6.311 New Jersey Uniform Interrogatories—Form E Auto Negligence by Plaintiff
Form 6.401 United States District Court for the Southern District of New York Permitted Questions
Form 6.501 King County, Washington, Pattern Interrogatories
Form 6.601 Iowa Pattern Interrogatories

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