Discovery: Interrogatories

§6.8a
		Introduction
		Commonly Asked Questions
		Demonstration
		Lecture Notes
		Discussion Points Answers

Introduction

For each discovery device, we provide general commentary, how to respond, specific techniques, and an example of the document.

Interrogatories are a good place to start when drafting discovery documents. In fact, if you have done a good job of drafting your "interrogs," your later discovery documents will be much quicker to create. That's because one of the best uses of Requests for Admissions and Requests for Production is to use them to corroborate the potential answers from some of the interrogatories.

For example, assume this is one of your Interrogatories:

15. On the night of the bachelor party, how much and what did you have to drink?

A corroborating Request for Admission might be:

3. Admit or Deny that you had multiple alcoholic drinks on the night of the bachelor party.

A corroborating Request for Production might be:

2. Please provide any and all receipts to which you have access, paper or electronic, on the night in question from the restaurant or bar where the bachelor party took place.

In addition, a good set of Interrogatories can morph into deposition questions, or eventually examination questions at trial. Interrogatories are, in some ways, foundational to the discovery process.

As you can see, the Interrogatories, if well crafted, can provide the basis for much of the discovery process, and more.

Demonstration Discovery Documents

The Good, the Bad, and the Ugly Time Sheets
Click on the examples of Time Sheets below to zoom in and compare. Yours should look like the Good example.

The Good	The Bad	The Ugly

Time Sheet Download
Click here to download a Time Sheet that automatically adds up your billable hours. You should keep track of any research or writing you do on behalf of your client, including the written assignments in this chapter.