Interrogatories are written questions that may be sent to any person or legal
entity who is a party to the lawsuit (plaintiff or defendant). They may not be
sent to persons who are not parties to the litigation. Most jurisdictions limit the
number of questions that can be asked and the number of sets of
interrogatories that can be sent. The questions are directed to the party
personally, but they are sent to the party’s attorney and the attorneys
representing all the other parties to the litigation. The attorney gives the
questions to the client and either asks the client to prepare a set of draft
answers or has a paralegal work with the client to prepare the draft.
Once the draft answers are prepared, the attorney edits this draft to prepare
answers that are technically correct and provide the requested factual
information, but provide as little speculation from the client as possible. If the
question is even slightly ambiguous, the attorney will refuse to provide an
answer until the ambiguities have been resolved. This process of disputing the
interrogatories can take several months and one or more hearings before the
judge. Interrogatories can be a cost-effective way of collecting information, but
in practice they are often abused.