Objections and Responses to Interrogatories
(GA)

Summary

This template may be used when responding to uniform and non-uniform interrogatories served on you or your client in a civil lawsuit in a Georgia state court. It contains practical guidance, drafting notes, and alternate clauses. The scope of discovery under Georgia's Civil Practice Act is broad. Interrogatories must be relevant to the claim or defense of any party. They are permissible if the information sought is reasonably calculated to lead to the discovery of admissible evidence. See O.C.G.A. §§ 9-11-26(b)(1); 9-11-33(b)(1). Note that the disclosure does not have to be admissible to be discoverable. You must answer each interrogatory "separately and fully in writing under oath" unless you are asserting an objection. See O.C.G.A. § 9-11-33(a)(2). If you object to an interrogatory, you must provide a basis for the objection in lieu of the answer. See O.C.G.A. § 9-11-33(a)(2). A failure to object may result in a subsequent waiver of that objection. See Ale-8-One of Am., Inc. v. Graphicolor Servs., Inc., 166 Ga. App. 506 (1983). If a response to an interrogatory may be ascertained from your client's business records, you may respond by identifying the responsive documents and producing them to the requesting party. See O.C.G.A. § 9-11-33(c). For more information on interrogatories in Georgia, see Interrogatories: Responding to Interrogatories (GA) and Interrogatories: Drafting and Serving Interrogatories (GA).