Section 3.19 Contents of the Answers

• Library: Discovery 2015

The answers must be under oath, and each interrogatory must be answered separately and fully. A full disclosure requires not only the information known to the answering party but also knowledge possessed by the party’s investigators, insurer, agents, or representatives. State ex rel. Pete Rhodes Supply Co. v. Crain, 373 S.W.2d 38, 45 (Mo. banc 1963). Some, but not all, information known to a party’s attorney is imputed to that party and, therefore, required to be included in answers to interrogatories. In Willis v. Brot, 652 S.W.2d 738, 739 (Mo. App. E.D. 1983), the court held that information that is imputed from the attorney to the party is that which relates to the facts discovered or information developed by the attorney for the trial of that action and may not include information relating to other actions in which the attorney was involved and information that is sought for the purpose of impeaching the party’s expert.

While parties are required to disclose information reasonably available to them, they are not required to...