Tips & Tactics
Using Interrogatories ...
The use of interrogatories can narrow issues of fact before taking depositions (and certainly before going to trial) giving you a decided advantage over those who take depositions before they know what to ask or those who foolishly go to trial without first discovering all the facts of the case.
Interrogatories are nothing more complex than carefully written questions that must be answered under oath in writing. When drafting interrogatories, be careful to ask your questions in such a way that only one answer (i.e., the answer you want) is possible.
IN THE THIRTEENTH JUDICIAL CIRCUIT COURT
Case No. 2007-123
PLAINTIFF'S FIRST SET OF INTERROGATORIES
PLAINTIFF Peter Plaintiff propounds the following interrogatories to defendant Danny Defendant.
RESPECTFULLY SUBMITTED this __ day of _________ 2007.
By asking questions like this you can easily force the other side to provide written answers under oath. With such sworn answers in the court's record you are better prepared to take depositions. In many cases, you may be able to win your lawsuit with nothing more!
Notice that each of the questions in this example is narrow, aimed at particular facts in a particular time period. Broad questions will not give you the results you need. Focus your questions.
Don't rely on "form books" or other people's cookbook methods to win your lawsuit. Every case is different. If you work with blank forms or legal cookbooks, you may miss a form's purpose! After all, filling in a form when you don't know what needs to go in the blanks isn't smart. Content is more important than form. It is content that gives a form its effectiveness.
The official Rules of Court handbook for your state (available from Thomson-West at 1-800-344-5009) will give you the official format for various forms but will not tell you the essential content that gives the forms' effectiveness. Our step-by-step lawsuit self-help course will do that for you!
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