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Litigation terms

Interrogatories

Interrogatories are written questions served on another party in litigation that must be answered in writing, under oath, within a set time — one of the core written-discovery tools alongside document requests and requests for admission.

Updated

Under Federal Rule of Civil Procedure 33 a party may serve up to 25 interrogatories (including subparts) absent leave of court; state limits vary. Answers are signed under oath by the party; objections are signed by counsel. “Contention interrogatories” — state all facts supporting your claim that… — probe the basis of the other side’s positions.

Why it matters in practice

Interrogatory answers are party admissions, usable at trial and deposited on the record early — which makes them a favorite source of prior inconsistent statements when testimony later drifts. Drafting discipline runs both directions: questions should be tight enough to survive objection but broad enough that evasion is visible, and answers must be written knowing every word may be read back to a jury. Rule 33(d) adds a wrinkle: a party may answer by pointing to business records where the burden of finding the answer is roughly equal — an invitation to bury, and a reason to inventory what was actually produced.

In the fact record

Interrogatory answers belong in the case chronology, not in a separate binder: dated, attributed, and checked against testimony and documents like any other statement. Answers that conflict with the record are leverage — if someone is tracking the conflicts.