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| Answers
to Interrogatories
NOTE
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STATE
COUNTY, SS.
NAME OF COURT
CIVIL DOCKET NO.
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Name of
Plaintiff
v.
Name(s)
of Defendant(s)
Defendants
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PROPOUNDED BY JAYNE SMITH John/Jane
Doe, pursuant to Rule 33 of the [state]
Rules of Civil Procedure, hereby responds to each numbered paragraph of
the Interrogatories propounded by Jayne Smith follows:
GENERAL OBJECTIONS A.
Your name objects to Jayne
Smith's
First Set of Interrogatories to the extent that they seek to impose
upon
John/Jane Doe obligations or burdens which are greater than, or
inconsistent
with, Rule 33 of the [state] Rules of Civil Procedure.
B.
John/Jane Doe objects generally
to Jayne
Smith's First Set of Interrogatories on the grounds that they are
overly
broad and burdensome. John/Jane Doe has made a good faith effort
to respond to the Interrogatories, but reserves the right to object to,
and to move to have vacated, all of Jayne Smith's Interrogatories.
C.
The following responses and
objections
are based upon information now known. John/Jane Doe has not yet
completed
discovery or preparation for trial in this action and therefore will
supplement
these responses and objections to the extent required by the [your
state] Rules
of Civil Procedure.
D.
Without waiving these objections
and
by way of response, John/Jane Doe provides the following responses.
ANSWERS TO INTERROGATORIES Interrogatory
1. [The rule
requires that you copy the interrogatory and put the
answer
below it, but the answer alone
is also
acceptable.
When you are drafting a Rule 37 Motion to Compel Answers to
Interrogatories
which you propounded (sent to the other side), you should put both your
interrogatory and their answer . . . so that you don't force the judge
to shuffle between pleadings/papers.]
Answer to Interrogatory 1. My name is John/Jane Doe. I reside at XX Any Street, Anywhere, State. I object to the remainder of the interrogatory as being irrelevant and invasive of his/her privacy. . Interrogatory
4.
.
. .
Answer to Interrogatory 4. John/Jane Doe has not determined who his/her expert or experts shall be, if any, at trial. John/Jane Doe reserves the right to update this answer to this interrogatory and its subparts at a later time when that decision is made. You should add the following objection at the end of all your answers but above your signature. Your
name states under the penalty of perjury
that he/she has read the foregoing Interrogatory answers and knows the
contents thereof; that said answers were prepared with the assistance
and
advice of counsel [only if they were]; that the answers set
forth
above, subject to inadvertent or undiscovered errors, are based on and
therefore necessarily limited by the records and information still in
existence,
presently recollected, and thus far discovered in the course of the
preparation
of these answers; that John/Jane Doe reserves the right to make any
changes
in the answers if it appears at any time that omissions or errors have
been made therein or that more accurate information is available; that
subject to these limitations the Interrogatory answers are true to the
best of his/her knowledge, information, and belief.
__________________________________
Your name |
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