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Interrogatories are “questions” sworn to under oath. 

That’s it.  Interrogatories are “questions” sworn to under oath. 

Here is an example from a child custody case:  If you contend that it is in the best interest of the child that you be appointed sole managing conservator or joint managing conservator with the rights to establish the domicile of the child and to receive child support, state each fact that is known to you or reported to you by others and the names of those other reporting persons) that supports your contention. That question is pretty broad and subject to objection.  It requires the responding party to “marshall” their evidence which is not required.  The question is also pretty broad – each fact.  Take a closer look at the interrogatory.  What is it asking in legalease?  It is asking for what facts support your contention that you should get custody. There it is.  This is an answer from one of our cases (generally), father should be awarded the primary designation because father has been the primary caretaker of the children while mother is a professional who spends long hours in her employment.  It is father who gets the child up for for school, gets them dressed, makes breakfast, makes their lunch, and drops them off on the way to school.  Mother is a manager of a retail establishment most everyday in her employment from Monday to Sunday.  She has little interest in the children.  Upon her return to the home at the conclusion of the day, she retreats to her bedroom and pretty much keeps to herself.  Father picks up the children from school, makes their dinner and sees to their homework. When the children are not doing their homework, father and the children enjoy playing board games, X-Box, and watching movies on TV.  

 The right to ask these interrogatory questions come from the Texas Rules of Civil Procedure 191, 192, 197 and 215.3

193.1 – “A party must respond to written discovery in writing within the time provided by court order or these rules. When responding to written discovery , a party must make a complete response, based on all information reasonably available to the responding party or its attorney at the time the response is made.  The responding party’s answer, objections, and other responses must be preceded by the request to which they apply.”

190.3 – “Interrogatories. Any party may serve on any other party  no more than 25 written interrogatories, excluding interrogatories asking a party only to identify or authenticate specific documents.  Each discrete subpart of an interrogatory is considered a separate interrogatory.” 

When we receive interrogatories from the opposing counsel, we will immediately mail a copy to you, and will we ask you to look them over and to begin to jot down any information you have readily at hand that is responsive to the questions.  Some questions will require simple answers such as your full name, any other names you have be known by now or at some time in the past, your Social Security Number, your address, your prior addresses, and so forth.  You may not know, or may not vividly remember all of the answers to all of the questions – do not be concerned about it at this point.  Some of the information to be disclosed will already be in our case file.  Simply do your best to recall the information needed to answer the questions.

Take a sheet of paper (you will need several) and write down “1” on the top of it.  Then write out your answer.  Take a second sheet of paper and write down “2” on the top of it. Then write out your answer.  Follow this same procedure for each interrogatory.

When you have jotted down all of the answers that you know or that you believe to be true to the best of your recollection, you should immediately call our office to schedule an appointment.  There are strict time limits for filing objections and responses to interrogatories and other forms of discovery.  When you visit our office, a member of our staff will sit down with you to review the interrogatories and to begin to prepare your answers in final form.  At this appointment we will discuss any concerns you have about the disclosure of personal or sensitive information, and we will work together with you to answer the questions as fully as possible.  After meeting with you, we will prepare your answers and will have you return to our office to review the final document and to sign your answers under oath, before a notary public.  When they have been prepared and signed, we will serve them on defense counsel.

If you fail to answer the interrogatories, your responses to similar questions at trial may be barred. 

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