Section 9.13 Interrogatories

• Library: Sources of Proof (2014 Ed.)

1. (§9.13) Interrogatories

Answers to interrogatories are often used at trial to prove foundational or basic facts necessary to submission of the case. An adverse party’s answers to interrogatories can simply be read to the jury as admissions of a party opponent. See:

· Gibson v. Newhouse, 402 S.W.2d 324 (Mo. 1966)

· McClanahan v. Deere & Co., 648 S.W.2d 222 (Mo. App. S.D. 1983)

· In re Estate of Mitchell, 610 S.W.2d 681, 690 n.5 (Mo. App. E.D. 1980)

· Pyles v. Bos Lines, Inc., 427 S.W.2d 790 (Mo. App. E.D. 1968)

This is true even though the answer may have been amended or supplemented, in which case both answers are read to the...