Understanding Interrogatories in the Legal Discovery Process

Attorney reviewing interrogatories document during the discovery process in a California civil lawsuit.

When most people think of lawsuits, they imagine courtroom drama, passionate arguments, and a final verdict. What often gets overlooked is the lengthy and detailed process that happens before trial—known as discovery. One of the most widely used tools in discovery is called interrogatories.

What Exactly Are Interrogatories?

Interrogatories is a set of questions that one side sends to the other in a lawsuit. The sending party composes the questions, serves them to the opposing side, and the recipient must reply in writing, under penalty of perjury, within the deadline specified in the rules—typically thirty days in federal and many state jurisdictions.  

Because the answering party answers under oath, the answers are treated as equivalent to live testimony. A falsehood, omission, or failure to respond can expose the deceitful party to sanctions, including contempt, dismissal, or the right to have favorable presumptions made in the case.

Why Are Interrogatories Important?

Interrogatories serve a number of strategic purposes in litigation:

• Fact-Finding: They allow a party to uncover details about the other side’s claims, defenses, and evidence.

• Narrowing Issues: By asking precise questions, attorneys can clarify what is truly disputed and what is not.

• Identifying Evidence: Responses often point to documents, witnesses, or events that may later be investigated further.

• Building Trial Strategy: Attorneys can use the answers to shape their arguments, decide on depositions, or prepare for cross-examination.

In short, interrogatories are a way of putting the other side on record—pinning them down to a story that they cannot later change without consequences.

Two Main Types of Interrogatories

Form Interrogatories

1. Pre-approved, standardized sets of questions provided by the court system.

2. They save time and are commonly used in routine cases like personal injury or contract disputes.

3. Example: “State your name, address, and employment history for the past five years.”

Special Interrogatories

1. Custom, case-specific questions written by an Attorney.

2. These allow one party to dig deeper into unique facts of the case.

3. Example: “Describe in detail all conversations you had with the plaintiff about the contract dated March 5, 2024.”

Rules and Limitations

While interrogatories can be powerful, they are not unlimited. Courts impose rules to prevent abuse:

• Numerical Limits: For instance, the Federal Rules of Civil Procedure (Rule 33) generally limit each party to 25 interrogatories unless the court grants more.

• Relevance Requirement: Questions must relate to the issues in the case; irrelevant or overly broad questions can be objected to.

• Burden and Privacy: Courts may block questions that are unreasonably burdensome or invade personal privacy without good reason.

The responding party may object to a question, but objections must be clearly stated and justified.

How Are Interrogatories Answered?

• Written and Sworn: Answers are provided in writing, signed by the party, and sworn under oath.

• Complete and Truthful: Parties must answer fully; evasive or incomplete answers can lead to motions to compel.

• Potential Sanctions: Failure to answer, or providing false information, can result in penalties, including fines or adverse rulings.

Sample Interrogatories in Action

To make things concrete, here are a few examples of what an interrogatory might look like in real life:

• “Identify all individuals who witnessed the accident on June 1, 2025.”

• “State all facts supporting your claim that the defendant failed to deliver the contracted goods.”

• “List all communications between you and the plaintiff regarding the disputed property.”

Each of these requires the responding party to commit to specific facts that can later be tested in depositions or at trial.

Final Thoughts

Interrogatories may not be the most glamorous part of litigation, but they are one of the most critical tools for uncovering the truth before a case goes to trial. They help clarify disputes, identify key evidence, and narrow the issues in contention. Because responses are given under oath, they carry significant weight and can shape the course of a lawsuit.

Taking interrogatories seriously is essential. Well-prepared answers provide clarity, while incomplete or evasive responses can create legal risks. Understanding how they work helps parties navigate the discovery process more effectively and move closer to resolving their dispute—whether through settlement or trial.

Need any help? Contact Sari Law Firm today to schedule a consultation and get expert guidance on discovery and interrogatories in California courts.

“Sari Law Firm proudly serves clients throughout Los Angeles, Irvine, Santa Ana, and all of Orange County.”

FAQ

1. What is the main purpose of interrogatories in a lawsuit?

Interrogatories are written questions used to gather facts and clarify issues before trial. They help both sides understand the strengths and weaknesses of their cases.

2. How long do I have to respond to interrogatories in California?

In most California civil cases, you must respond within 30 days after receiving them (per California Code of Civil Procedure §2030.260). Extensions can sometimes be granted by agreement.

3. What happens if I fail to respond to interrogatories?

Failing to respond can lead to a motion to compel, court sanctions, or even losing certain legal defenses. Courts take written discovery obligations seriously.

4. Can I object to an interrogatory I find irrelevant or invasive?

Yes. You may object if the question is irrelevant, overly broad, or violates privacy. However, objections must be specific and justified under the California Civil Discovery Act.

5. What’s the difference between form and special interrogatories?

Form interrogatories are standardized questions provided by the court; special interrogatories are custom-written by attorneys to target unique facts of the case.

6. Should I answer interrogatories without a lawyer?

It’s strongly recommended to consult an attorney. Because answers are given under oath, mistakes can harm your case. Sari Law Firm can guide you in preparing accurate and compliant responses.