Instructions: Interrogatories (Written Questions to Other Parties)

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This packet provides general guidance about asking written questions to another party in the case.
This template provides guidance only. Using this template does not guarantee any result in your case.

WHEN TO SEND INTERROGATORIES

  1. Figure out when you can first serve interrogatories. When the case was filed, the Clerk issued a document called an Initial Scheduling Order, which set the date of the Case Management Conference. Normally, you can serve discovery (such as these interrogatories or document requests) after this Conference, though the Court may set a different deadline at the Conference.
  2. Figure out the discovery deadline. After the Conference, the Court will send out an updated Scheduling Order setting the discovery “cutoff.” You must send your final set of interrogatories 33 days before the discovery cutoff (or hand-serve 30 days before).

HOW TO COMPLETE THIS TEMPLATE FOR INTERROGATORIES

  • Fill in the case information. Fill in all blanks on the first page.
  • Review the Definitions Section. Review the standard definitions, and add in any definitions specific to your case that will make it easier to understand your interrogatories.
  • Write your Interrogatories. Write simple questions that may help you prove or defend your case. You may send up to 25 interrogatories to each party. You do not have to send them all at once. If this is not the first set of interrogatories you are sending to this party, renumber the interrogatories, starting with the number you left off on last time.
  • Review, number the pages and sign. Read the entire document to make sure your Interrogatories are clear, focused on this case, and that you are not repeating any questions. Count the number of pages. On each page, write in the page number and the total. Sign and date.
  • Prepare the Certificate of Service. Each document that you file must be “served” on each other party, usually by sending it in the mail. Follow the instructions on the Certificate of Service.
  • Mark your calendar. The responding party has 30 days (33 days if you serve by mail) to send you a written response. If you need help with getting complete responses to your questions, make an appointment at the Legal Help Center (see page 1).

SERVING YOUR INTERROGATORIES

  1. Make copies. Once the documents are complete, make one copy for each party to the case.
  2. Serve the Requests. Be sure the Interrogatories and Certificate are served on each party. Do not send a copy to the Court.

TIMELINE: AFTER INTERROGATORIES ARE SERVED

The timeline below lists what generally happens after Interrogatories are served. The Legal Help Centers (see page 1) can provide guidance about these steps and have many other templates for you to use.

  • Requests served
  • Responding party provides written response to each interrogatory (30 days+ 3 for mail)
  • If responding party objects or fails to respond, the requesting party follows up (immediately after responses were due)
  • Parties follow Judge’s rules for resolving disputes about discovery (ongoing, but no later than the “discovery cutoff”)

STAY UP TO DATE

  1. Update your contact information. File a notice with the Clerk right away if your address, email, or phone number changes, or you may miss important deadlines, causing you to lose your case.
  2. Check your mail. Be sure to check regularly for documents from the Court and opposing side.
  3. A list of all of the documents that have been filed, and (usually) the documents themselves can be viewed online. See Chapter 7 of the Handbook for Pro Se Litigants, and contact the Legal Help Center for information about how to access the documents (see page 1).

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