Section 3.1 General and Tactical Considerations

• Library: Discovery 2015

The extent to which interrogatories may be employed in discovery is limited by the fact that they may only be served on parties to the action. Even with regard to discovery from other parties, interrogatories often play a separate and distinct role, and in most cases, they should not be considered as an exclusive form of discovery.

Some of the disadvantages of interrogatories, as opposed to depositions, include the following:

• The actual answers are usually framed by the party’s attorney.

• The control of evasive or incomplete answers is more burdensome and less effective than in depositions.

• The element of spontaneity is lost.

• There is no opportunity to promptly pursue new lines of interrogation prompted by particular answers.

• There is no opportunity to observe the...