Litigation

Discovery Tip: Using Model Interrogatories to Fend Off Objections to Discovery

By Evan Schaeffer

In many jurisdictions, you can find court-approved interrogatories, such as model interrogatories for motor vehicle, medical malpractice, and divorce cases approved by the Illinois Supreme Court.

Even if your case doesn't fall under one of the standard categories, you can still use the model interrogatories for drafting your own discovery. Not only does the use of a form make drafting discovery easier, but it will also help you later in fending off objections. The closer your discovery is to a court-approved form, the easier it will be to argue that your opponent's objection is not well-taken.

So powerful is the argument that "the interrogatory my opposing counsel is objecting to is identical to one approved by the courts," that it often makes sense to look at court-approved interrogatories when preparing to argue objections, even if you didn't use the model interrogatories in the first place.

Related posts:

1. "A Tip for Drafting Interrogatories: Less Can Be More."

2. "Sample Interrogatory: Persons with Knowledge."

Full post as published by The Illinois Trial Practice Blog on August 19, 2008 (boomark / email).