AuthorAshley S. Lipson
Like a long range missile
an interrogatory does its damage
from a safe distance away.
Chapter 6
Table of Contents
§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
§6.70 Enforcing the Requests
§6.71 No Responses by Opposition
§6.72 Evasive or Improper Responses by Opposition
Contents continued on next page
Guerrilla Discovery 6-2
§6.80 The Forms That You Need
Form 6.1 Plaintiff’s Interrogatories to Defendant
Alternate Clauses
[A] Establishing Jurisdiction
[B] Attack Basic Contract Defenses
[C] Attack Defense Claims of Contributory Negligence
[D] Attack Defense Claims of Comparative Negligence
[E] Attack Defense Claims of Third Party Negligence
[F] Attack Defense Claims of Third Party Intervention
[G] Attack Defense Claims of Assumption of Risk
[H] Attack Defense Claims of Failure to Mitigate Damages
[I] Attack Defense Claims of Lack of Respondeat Superior
[J] Attack Claims of Preemption [State and Federal]
Form 6.2 Defendant’s Interrogatories to Plaintiff
Alternate Clauses
Personal Identification
Representative Status of Litigant
Assignee Status of Litigant
Marital Status of Litigant
Educational Status of Litigant
Employment History of Litigant
Military Status of Litigant
Criminal Record of Litigant
Prior Lawsuits of Litigant
Liability Insurance of Litigant Defendant
Business Entity Identification
[A] To a Potential Agent
[B] To Sole Proprietorship
[C] To Joint Venture
[D] To General Partnership
[E] To Limited Partnership
[F] To Limited Liability Company [LLC]
[G] To Corporation
Questions to an Independent Witness
Form 6.3 Interrogatories - Contract/Accounting Related Actions
Breach of Written Contract
Action on Account Stated
Action Based on Quantum Meruit
Form 6.4 Interrogatories - Tort Related Actions
Basic Damages
[A] Physical Injury
[B] Emotional Injuries
[C] Loss of Earnings
[D] Hedonic Injuries
Failure to Mitigate
Collateral Sources
Assault and Battery
False Arrest or Imprisonment
Dog Bite Action
6-3 interroGatories
Form 6.5 Interrogatories - Defamation
Form 6.6 Interrogatories - Fraud
Form 6.7 Interrogatories - Vehicular Negligence
Rear End Collision [Supplements and Alternatives]
Traffic Light Intersection Collision [Supplement]
Stop Sign Intersection Collision [Supplement]
Head-On Collision [Supplements and Alternatives]
Pedestrian Collision [Supplements and Alternatives]
Form 6.7(a) Interrogatories - Vehicle/Bicycle Accident
Form 6.8 Interrogatories - Malpractice
Medical Malpractice
[A] Generic Questions to Defending Physician
[B] Failure to Diagnose, Questions to Defending Physician
[C] Failure to Treat, Questions to Defending Physician
[D] Improper Medication, Questions to Defending Physician
[E] Lack of Informed Consent, Questions to Defending
[F] Generic Questions to Hiring Health Care Facility
Attorney Malpractice
Accountant Malpractice
Priest/Clergy Malpractice
Form 6.9 Interrogatories - Premises Liability
Contention Interrogatories
Attractive Nuisance [Supplement]
Criminal Conduct or Assault
Form 6.9(a) Interrogatories - Workplace Liability
General Unsafe Work Area
[A] Questions to Defending Employer
Unsafe Work Area - Machine Related Injury
[A] Questions to Defending Employer
Form 6.9(b) Interrogatories - Sexual Harassment in the Workplace
Form 6.10 Interrogatories - Product Liability
Form 6.11 Interrogatories - Domestic Relations
Divorce or Separation
Spousal Abuse
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
Form 6.17 Objections to the Requesting Party’s First Set of

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