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Devon Glass
Devon Glass
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Interrogatories: A Written Deposition


Continuing with Steve Lombardi‘s excellent article on interrogatories posted over at his blog, and continuing the theme of the week between Steve, Mike, Rick, Wayne, and Pierce, I’d like to add my two cents on the issue of interrogatories and what they mean to a claim. The difficult thing about writing on many topics after Steve has written on the same subject is this: he writes to damn much and doesn’t leave much for the rest of us to discuss. Steve, how about you stop writing novels and start writing chapters?

On to the issue at hand, interrogatories. It sounds really formal and imposing, but as Steve points out, they are really just questions about what happened to cause your injury, what medical treatment you’ve received, and how the injuries have affected your life. When you read the questions as they are written, it probably feels like you are taking a standardized test and it’s your job to figure out which word in the sentence is a noun. Maybe that would be easier.

One thing that will hopefully set your mind at ease is that there is no answer key for the questions. If you don’t know an answer to one of the questions, you can say you don’t know. The only wrong answer you can give is a lie or a deliberate misrepresentation of the facts. Otherwise, you should do your best to answer the questions to the best of your ability and knowledge. Another thing that should hopefully set your mind at ease is that your attorney will be reading through your answers to make sure you answer the questions appropriately.

Figuring out how to answer the question can be difficult. Many times the questions are written in such a way that it seems deliberately confusing. If you encounter a question you don’t know the answer to, take a minute to think about what the question is asking of you, and if you still are unsure how to answer, skip the question and move on to questions you feel more comfortable answering. You may get an idea on how to answer a question based upon reading and answering other questions, but even if you don’t have a clue what to write, that’s okay. You should ask your attorney to help you with any questions you are unsure about. However, this does not mean you don’t have the responsibility to answer the questions yourself, just that your attorney can help explain what the question is asking so you can provide the answer.

You may be wondering, why am I supposed to answer the questions? Doesn’t my attorney know this stuff? The answer is yes and no. Of course your attorney should be able to answer most, if not all, the questions in the interrogatories. The point of interrogatories is to find out what you know, not what your lawyer knows. Another thing to think about is this, if your attorney spent all his time answering interrogatories for his clients, he would have no time to investigate your claim or help more than a dozen or so people. Lawsuits take lots of time and energy to prepare and investigate and your attorney needs some help from you to make the job a bit more manageable. Would you rather your attorney spend all his or her time answering questions for you or investigating your claim as vigorously as possible?

That’s pretty much it for interrogatories from my perspective, although I am sure that Rick, Wayne, Mike or Pierce will have more to say on the matter. Be on the look out for more posts in our continuing series on being a client.

Join these lawyers for more on commonly asked questions that clients ask.

Wayne Parsons, Devon Glass, Mike Bryant, Rick Shapiro and Pierce Egerton

I was in an automobile accident. What should I do? Ten Tips For Hawaii Drivers, Wayne Parsons on September 14, 2009 – 3:59 AM EST.

What would a caveman bring to meet with the lawyer?, Steve Lombardi , September 15, 2009 11:00 AM

Solving Legal Problems, Being a Client, Back to the Basics, Steve Lombardi , September 15, 2009 8:48 AM

Car Accident Injury Client: What Makes the Case Good or Bad? (The Collision & Medical Care) , Rick Shapiro September 16, 2009 9:38 AM

Being a Client: More Tips To Help Improve Your Case If You’ve Been In An Car Accident , Devon Glass , September 17, 2009 8:39 AM

Presumed Guilty: How to Avoid Having Insult Added to Injury When You’ve Been Hurt in a Car Crash, Pierce Egerton , September 18, 2009 4:28 PM

What To Do After An Accident When The Adjuster Is There First, Mike Bryant| September 19, 2009 6:26 PM

What Questions Is The Lawyer Going To Ask Me At The Initial Interview For My Injury Or Death Case?, Wayne Parsons | 20 September 2009 12:01

What makes a case good or bad?, Steve Lombardi, 21 September 2009 12:57 PM

What To Do After An Accident When The Adjuster Has A Tape Recorder,Mike Bryant , September 23, 2009 10:01 PM

Do I have a good or a bad case? Devon Glass, September 24, 2009

What are interrogatories and how do I answer them? Steve Lombardi, September 29, 2009


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  1. Mike Bryant says:
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    Good point on why the client needs to answer the questions, and also big that they be truthful. I often find that when clients start with the answers you get information that they haven’t told you before or that they didn’t think about before. They are a great way to help prep the case and cover the areas that need to be looked at again.

  2. Steve Lombardi says:
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    Devon: Nicely done; you’ve covered the subject well. See I didn’t cover what you did. Your point about answering the easier questions first and then moving onto the tougher ones is sound advice about how to approach answering interrogatories. But, you did get me laughing. I’ve often wondered if we shouldn’t take a copy of the best set of defense interrogatories and hand them to the client at the beginning of the case. That might get them ready for what is about to come after suit is filed.