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Interrogatories are “questions” sworn to under oath. 

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 , aparty 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.

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