flash

Interrogatories

A.  IDENTIFICATION & AUTHENTICATION INTERROGATORIES

 

The following identification and authentication interrogatories do not count against {party}’s limit of 25 interrogatories. 

 

INTERROGATORY 1:  Identify all insurance policies relevant to this suit.  {Ask for documents in request for production.}

 

INTERROGATORY 2:  Identify all invoices relevant to the contract that is the subject of this suit.  {Ask for documents in request for production.}

 

INTERROGATORY 3:  Identify all documents relevant to {identify specific occurrence or transaction, e.g., the Master Sales Agreement that is attached as Exhibit A to Plaintiff’s Original Petition}.

 

INTERROGATORY 4:  Is the {identify document, e.g., contract} attached to these interrogatories as Exhibit {letter} a true and correct copy of the original?

 

B.  STANDARD INTERROGATORIES

 

The following standard interrogatories count against {party}’s limit of 25 interrogatories. 

 

INTERROGATORY 1:  Identify each person answering these interrogatories, supplying information, or assisting in any way with the preparation of the answers to these interrogatories.

 

INTERROGATORY 2:  Identify every person who is expected to be called to testify at trial, including your experts. 

 

 

INTERROGATORY 3: Identify all discoverable, consulting experts, that is, consulting experts whose work has been reviewed by the testifying expert. For each expert named, provide the following information:

  1. The expert’s name, address, and telephone number.
  2. The expert’s current résumé and bibliography.
  3. The facts known to the expert that relate to or form the basis of the expert’s mental impressions and opinions formed or made in connection with the case, regardless of when and how the factual information was acquired.
  4. The mental impressions or opinions of the expert formed or made in connection with the case and any methods used to derive them.
  5. Any bias of the expert.
  6. Identify all documents and tangible things, including reports, models, or data compilations, that have been provided to, reviewed by, or prepared by or for the expert, so the documents or tangible things may properly be sought by a request for production.  {Ask for documents or tangible things in request for production.}

INTERROGATORY 4:  Identify all experts who have firsthand factual information about the case and provide a brief statement of each expert’s connection with the case.  {If the attorney believes opposing counsel has overlooked the names of experts with firsthand factual information about the case, add this question to the list of standard interrogatories.  Otherwise, omit.}  

 

INTERROGATORY 5:  State the legal theories and describe in general the factual bases for your {claims/defenses}.

 

 

INTERROGATORY 6:  Do you make the {legal/factual} contention that {identify specific legal or factual contention}?

 

INTERROGATORY 7:  Identify every person who has impeachment or rebuttal evidence and describe the evidence each person has.  If you have enough information to anticipate the use of impeachment or rebuttal evidence or witnesses, you must provide that information. {Ask for documents in request for production.} 

 

INTERROGATORY 8:  If you have ever been convicted of a felony or a crime involving moral turpitude, state the nature of the charge and the date and place of arrest and conviction.

+91.99903.93294

Certifications

 

Request a Quote

TwitterFacebookLinkedInMySpace

Subscribe Newletter
Subscribe Newletter

Litigation Outsourcing in 2010
2010 recent study suggests daunting picture to corporate counsel struggling with shrinking legal budgets. Large cap companies will see an increase in matters in 2010 as compared to 2009. During the s...

Teens Know Distracted Driving Car Accidents Kill, But Text, Call Anyway
In a very interesting reporting by USA Today reveals that America’s teens seem to have a disconnect between what they’ve been told and what they do. They’ve been told and given fair warning that...

Personal Injury Law – Settlement
The term Personal Injury Settlement, is term used to describe a monetary payment or monetary award that can be given to the victim of a personal injury loss for the release of their legal claim for da...

Reality of Insurance Company Doctors
All too often insurance company doctors attempt to discount the injuries of accident victims. What can occur is the insurance doctor performs a one-time exam of the insured lasting only a few minutes....

Reduce Your Off-Shoring Bills- Xxon’s Tips For Foreign Law Firms
The basic reason to off-shore any work is to reduce costs, be it a legal off-shoring or any knowledge off-shoring. Such being so every effort and endeavor should be made to keep the off-shoring bills ...

Tips For U.S. People of The Points to Take Care When a Mishap Occurs at Shopping Centre (Eg: Wal-mart). Adoption of These Tips Helps The Law Firms and Attorneys a Lot to Contest The Case Successfully
As a consumer you are always looking for low prices and bargains when shopping for you and your family, especially if you can go to a one-stop super-center such as Wal-Mart where you can purchase all ...

Challenges For Law Firms and Attorneys When Client Often Speaks With an Insurance Adjuster and Almost Kill His Case
The Insurance adjusters work for insurance companies; they do not work for attorney’s client. It is their job to save money for the insurance company. They have no motivation to get you the most mon...

The Texas “Good Samaritan” Law: What Does it Means
Texas “Good Samaritan” Law designed to protect individuals who give emergency medical assistance to those in need. Most people know generally what is meant by the term “good Samaritan” but di...

Types of Personal Injury Losses
The term Personal Injury is the term commonly used to describe a physical injury an individual can sustained, usually after a traumatic event, such as an auto accident or a fall. Amputations - Car ac...

Paralegal World
Para-legal Job: Basically, Para-legal job includes research, drafting discovery requests/ responses, trial preparations, and work on legal billing fee analysis. Interesting thigh about Para-legal: ...

news bottom