Objections and Responses to Interrogatories
(IL)

Summary

This template is a set of objections and responses to interrogatories you may use in an Illinois circuit court civil case. You may use it as the complete answer to a set of interrogatories or in conjunction with your client's answers. It complies with Illinois Supreme Court Rule (Supreme Court Rule) 213 and includes common forms of objections and responses. The template contains practical guidance, drafting notes, and alternate clauses. Interrogatories are written questions a party serves on any other party, to be answered by the party served. The responding party must answer each interrogatory separately and fully in writing under penalty of perjury. You must respond to interrogatories within 28 days of service. See Ill. Sup. Ct. R. 213(d). A court may permit you to serve answers or objections after the 28-day window has expired if you demonstrate good cause. See Ill. Sup. Ct. R. 183; Defilippis v. Gardner, 368 Ill. App. 3d 1092, 1095 (2d Dist. 2006) (rejecting argument that party waived right to object by failing to timely respond). However, you should serve all objections and responses before your deadline expires if possible. You should consult with your client promptly upon receiving the interrogatories to determine whether you are likely to need additional time to respond. If you will need additional time, you should consult with counsel for the propounding party to determine whether they will voluntarily agree to an extension of the response deadline. If not, you should notice for hearing a motion for an extension of time to the response deadline. See Ill. Sup. Ct. R. 183. For more information, see Extending Time in Litigation (IL). For more information on responding to interrogatories, see Interrogatories: Responding to Interrogatories (IL) and Interrogatories: Responding to Interrogatories Checklist (IL). For more information on drafting and serving interrogatories, see Interrogatories: Drafting and Serving Interrogatories (IL) and Interrogatories: Drafting and Serving Interrogatories Checklist (IL). For template interrogatories, see Interrogatories (IL). For more information on discovery strategy, see Discovery Planning and Strategy (IL).