Interrogatories
(CT)

Summary

This template illustrates the general format of interrogatories that a party to a Connecticut civil action may use to obtain information from the opposing party during the discovery process. This template includes practical guidance, drafting notes, and alternate and optional clauses. Interrogatories are a frequently used discovery device, consisting of written questions propounded by one party to another. See Conn. Practice Book § 13-6(a). Interrogatories may relate to any matter within the permissible scope of discovery under Conn. Practice Book §§ 13-2–13-5, and the answers may be used to the extent permitted by the rules of evidence. Conn. Practice Book § 13-6(b). For discussion of the scope of discovery and limits on permissible discovery, see Scope of Discovery and Objections to Discovery (CT). The responding party must either answer the interrogatories in writing and under oath or object to them. See Conn. Practice Book §§ 13-7(a), (c), (d), 13-8. Interrogatories may be served without leave of the court any time after the return date on the summons. Conn. Practice Book § 13-6(a). In the following types of cases, you generally must use specified mandatory form interrogatories set forth in the Appendix of Forms to the Connecticut Practice Book, as applicable, instead of attorney-drafted interrogatories such as those included in this template: • Personal injury actions alleging liability based on the operation or ownership of a motor vehicle (see Form 201 (plaintiff's interrogatories); Form 202 (defendant's interrogatories)) • Personal injury actions alleging liability based on the ownership, maintenance, or control of real property (see Form 203 (plaintiff's interrogatories—premises liability); Form 202 (defendant's interrogatories)) • Actions claiming a loss of consortium (see Form 212 (defendant's interrogatories—loss of consortium)) • Actions for uninsured/underinsured motorist coverage benefits (see Form 213 (plaintiff's interrogatories—uninsured/underinsured motorist cases); Form 214 (defendant's interrogatories—uninsured/underinsured motorist cases)) See Conn. Practice Book § 13-6(b). Certain additional form interrogatories must be used if action involves a claim for workers' compensation benefits. See Conn. Practice Book § 13-6(b); Forms 208, 210. If a complaint includes some counts that are of the type specified by Conn. Practice Book § 13-6(b) and some that are not, use of the standard interrogatories is required only with regard to the counts that are covered by Conn. Practice Book § 13-6(b). The parties are free to draft and serve their own interrogatories for the other counts. See Restuccia v. Allstate Ins. Co., 2001 Conn. Super. LEXIS 860, at *3–4 (Conn. Super. Ct., Fairfield Jud. Dist. Mar. 22, 2001). If the standard form interrogatories are inappropriate or inadequate in a particular case in which they are otherwise required by Conn. Practice Book § 13-6(b), you may move the court for permission to serve different or additional interrogatories. See Conn. Practice Book § 13-6(b); but see Parisi v. Lakeview Ctr. Assocs., LLC, 2016 Conn. Super. LEXIS 1888, at *3–4 (Conn. Super. Ct., New Haven Jud. Dist. June 29, 2016) (denying motion for permission to serve nonstandard interrogatories in premises liability case because standard interrogatories found to be adequate). This template includes some generic interrogatories that should be useful in most cases in which use of the standard interrogatories are not required. Interrogatories specific to the facts and issues in the case should be inserted into this template as appropriate. For examples of specific interrogatory questions for use in various types of civil actions, see Bender's Forms of Discovery, Vols. 1–10 (Matthew Bender). Parties also usually include instructions and definitions in interrogatories. Instructions and definitions typically are placed before the individual interrogatories. Note, however, that you are required to use the instructions set forth in standard Forms 201–203 in all nonstandard interrogatories, unless you obtain leave of the court. See Conn. Practice Book § 13-6(f). Furthermore, the Practice Book includes standard definitions for certain terms and rules of construction that are deemed incorporated by reference into all discovery requests served under Conn. Practice Book § 13-1 et seq. See Conn. Practice Book § 13-1(b)–(d). You may not include any broader definition of a term defined in Conn. Practice Book § 13-1(c) in your interrogatories, but you may: • Define other terms specific to the particular litigation • Use abbreviations and • Include a narrower definition of a term defined in Conn. Practice Book § 13-1(c) Conn. Practice Book § 13-1(b). You may (and most attorneys do) serve the interrogatories in an electronic format (such as a word processing file) that allows the responding party to insert answers directly into an electronic copy of the interrogatories document. If you serve the interrogatories in paper form, you must leave sufficient space following each interrogatory to allow the responding party to insert an answer or objection. See Conn. Practice Book § 13-6(a). It is also recommended that the interrogatories document comply with general format requirements documents set forth in Conn. Practice Book § 4-1, although this is not technically required because interrogatories are not filed with the court. For details on general format rules, see Formatting Rules in Court Checklist (CT). The interrogatories should be served on the responding party's attorney, or directly on the responding party if not represented, and on all other parties to the action. See Conn. Practice Book §§ 10-12(a), 13-6(a). For details on service procedures, see Serving Documents Checklist (CT). Interrogatories should not be filed with the court. See Conn. Practice Book § 13-6(e). For more information on preparing interrogatories, see Interrogatories: Drafting and Serving Interrogatories (CT).