Objections and Responses to Interrogatories
(NC)

Summary

This template is objections and responses to interrogatories that may be used by a defendant in a North Carolina state case. This template contains practical guidance, drafting notes, and alternate clauses. Interrogatories are a frequently used discovery device, consisting of written questions propounded by one party to another. Interrogatories may relate to any matter, not privileged, relevant to the claims and defenses of any party. As the responding party, you must either answer the interrogatory under oath or provide a specific objection. See N.C. R. Civ. P. 33(a). The answers to interrogatories are admissions of a party and are otherwise admissible at trial to the extent permitted by the rules of evidence. See N.C. R. Civ. P. 33(b). When responding to interrogatories, take several tactical considerations into account. If your objection is deemed to be improper, you subject your client (and potentially yourself) to sanctions in litigation. You must have a thorough understanding of what objections are appropriate. When the interrogatories first are received, forward them to your clients with guidance as to what questions they must provide information and draft answers. Give them a deadline by which to respond, allowing sufficient time for the final responses to be prepared and served. In addition, forward the verification (see Verification below) to the clients at the outset and obtain the signed verification as that is often one of the more difficult aspects of finalizing the responses when they are eventually due. This template assumes the defendant is responding to interrogatories served by the plaintiff. If you represent the plaintiff or co-defendant, you should customize accordingly. For more on interrogatories, see Interrogatories: Drafting and Serving Interrogatories (NC) and Interrogatories: Responding to Interrogatories (NC).