Objections and Responses to Interrogatories
(Plaintiff to Defendant) (Federal)

Summary

This objections and responses to interrogatories template may be used by a plaintiff in a federal district court case to object and respond to a defendant's interrogatories. It includes 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, and proportional to the needs of the case. As the responding party, you must either answer the interrogatories in writing and under oath or object to them. See Wagstaffe Prac. Guide: Fed. Civil Proc. Before Trial § 35-I[A]. The answers are admissions of a party and, therefore, admissible at trial to the extent permitted by the rules of evidence. Rule 33(b) requires that you serve written objections and/or responses within 30 days of being served with interrogatories. There is a duty to provide information known and reasonably available to the client and counsel in response to the interrogatory. When the interrogatories are first received, schedule a time to discuss them with your client. Depending on your relationship with sthe client, it may be productive to forward them to your client with guidance as to what questions they must provide information and draft answers and a deadline by which to respond, allowing sufficient time for the final responses to be prepared and served. In addition, discuss the verification (see Verification below) with the client at the outset due, and ensure the client will provide it on time. For a full listing of key content covering fundamental civil litigation tasks throughout a federal court litigation lifecycle, see Civil Litigation Fundamentals Resource Kit (Federal). For more on interrogatories, see Interrogatories: Responding to Interrogatories (Federal) and Interrogatories: Drafting and Serving Interrogatories (Federal). For an in-depth discussion of discovery strategy and planning, see Discovery Planning and Strategy (Federal). For related templates, see Objections and Responses to Interrogatories (Defendant to Plaintiff) (Federal), Interrogatories (Plaintiff to Defendant) (Federal), and Interrogatories (Defendant to Plaintiff) (Federal)