Litigation

Interrogatories

By Ron Miller

The best advice for propounding, answering and following up on interrogatory answer is the one thing that few lawyers do: put thought into them as to exactly how you are going to use them at trial.   We get so much advice as lawyers as to what we should do.  As a result, we make a lot of diving impossible catches but miss too many fly balls. 

Think about what you are trying to prove at trial.  Think about the questions that box in the defendant's lawyer (in one direction or the other).  Think about the hard questions that you would like to get answers to read to a jury.   Think about the case individually.  Then draft your interrogatories and demand answers that fairly and honestly answer the questions.

Focusing just on this is better than reading a thousand differnet article on drafting interrogatories.

Full post as published by Trial Lawyer Resource Center on January 07, 2010 (boomark / email).