COUNTY, SS. NAME OF COURT
CIVIL DOCKET NO.
Name of Plaintiff
Name(s) of Defendant(s)
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:
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.
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.