Objections and Responses to Interrogatories
(NY)

Summary

This Objections and Responses to Interrogatories is a standard form attorneys can use to respond to interrogatories served by an adverse party in a New York state court litigation. This template includes practical guidance, drafting notes, optional clauses, and alternate clauses. Interrogatories are written questions that: • Seek detailed facts and information about the litigation issues • Request documents relevant to the required answers See N.Y. C.P.L.R. § 3131. The responding party must answer each interrogatory separately and fully in writing under the penalties of perjury. See N.Y. C.P.L.R. § 3133. If your client receives interrogatories, you should set up a meeting or conference call with your client as soon as possible to discuss the information and documents they must gather. Note that under the Uniform Rules for New York State Trial Courts, each party is limited to serving only  25 interrogatories, including subparts, unless the parties agree or the court orders otherwise. See 22 NYCRR 202.20. This rule applies to all Supreme Court cases, including those assigned to the Commercial Division. See 22 NYCRR 202.20, 202.70(g) (Rule 11-a(a)). In the event the propounding party serves more than 25 interrogatories, you should object on those grounds, specifically asserting the objection for each offending interrogatory. For a full listing of key content covering fundamental civil litigation tasks throughout a New York court litigation lifecycle, see Civil Litigation Fundamentals Resource Kit (NY). For more information on responding to interrogatories, see Interrogatories: Responding to Interrogatories (NY). For a checklist on responding to interrogatories see Interrogatories: Responding to Interrogatories Checklist (NY). For information on drafting and serving interrogatories, see Interrogatories: Drafting and Serving Interrogatories (NY) and Interrogatories: Initial Considerations Checklist (NY). For a checklist on drafting and serving interrogatories, see Interrogatories: Drafting and Serving Interrogatories Checklist (NY). For model interrogatories, see Interrogatories (NY).