L. Scope of interrogatories. Apolinsky, Esquire. TEX. The methods include an oral deposition, a written deposition, or a deposition for production of business records. Responding to written discovery including interrogatories, production of documents and requests for admission. Written By Michael L. What is the difference between Rules 31 and 33? What is the default maximum number of depositions? See Rule 30(a)(2). The person answering the questions does so under oath. arefully!)Depending on what type of witness you are deposing, your questions may vary. A copy of the interrogatories must be served on all parties to the proceeding. (1)Definition. Dec 19, 2022 · The purpose of interrogatories is to gather information and clarify factual issues in a legal proceeding. (NRCP 33; JCRCP 33) Aug 1, 2015 · In the practice of law, interrogatories are the most commonly method used in discovery, or in the effort to obtain information from an opposing party to a lawsuit. At the bottom are sample interrogatories the plaintiff can expect in a product defect, manufacturing defect, or defective warning case from the defendant. 060(d),2033. You can designate a witness by name or description ala Rule 30(b)(1); or as a corporate representative ala Rule 30(b)(6). For example, “the incident” or “the Apr 19, 2024 · Offers interrogatories for both plaintiff and defense and each set of interrogatories features a summary of the topics covered by the questions along with the numbers of the questions that relate to that topic. A quality interrogatory challenges the opposition party's Oct 9, 2018 · Interrogatories are written questions (or requests for specific information) that are sent from one party to another. pl:-ries: a written question required by law to be answered under the direction of a court ;esp: a written question directed by one party to another regarding information that is within the scope of discovery see also general verdict and special verdict at verdict, special interrogatory NOTE: Interrogatories are widely used as a May 30, 2024 · As amended through May 30, 2024. and the questions and the spontaneous answers are recorded by a court reporter for transcription in to a written text. Pa. 2d 114, 119-120 (3rd Cir. 01 | Interrogatories to Parties. Within thirty days thereafter the party so served may serve cross interrogatories upon each party or the attorney of record of each Jan 22, 2022 · 3. You can record the deposition by stenographic or audio or video means. Rule 31 allows depositions by written questions, enabling testimony collection without an oral examination, with all parties having the chance to contribute questions. GENERAL STEPSDraft Your Questions (. The thought goes, "Why would I choose testimony filtered through an attorney when I can go right to the source in deposition?" It's less common for attorneys responding to discovery to take that same tack. 1982). 3d 389. The plaintiff can send the interrogatories to the defendant, and vice versa. Except as otherwise provided herein, after commencement of an action, any party may serve upon any other party written interrogatories. Interrogatories to parties; service thereof. 2004), a video conference deposition was permitted where the defendant-deponent was the sole care giver for her ailing nonagenarian The party requesting the deposition is responsible for hiring a court reporter and paying the court reporter costs. Depositions. The focus in this issue is on interrogatories. The Contact a Georgia Civil Litigation Attorney. Sample Discovery: depositions, requests for admission and other discovery in personal injury cases. 2d 1487, 1497 (10th Cir. The right to privacy in, “California primarily derives from the California Constitution's Jan 12, 2010 · Each question separate and complete: Each interrogatory must be “separately set forth” and “full and complete in and of itself. [1. Parties submit questions ahead of time in this kind of deposition and the deponent answers only those questions. Although the field of inquiry that may be covered by depositions or interrogatories is as broad as when the interrogated party is called as witness to testify orally at trial, the First, the motion must be made no later than 30 days before the close of discovery. Parties may obtain discovery by one or more of the following methods: depositions upon oral examination or written questions; written interrogatories; production of documents or things or permission to enter upon land or other property, for inspection and other purposes; physical Written Interrogatories (Rule 25) Within 15 days after service, unless extended or reduced by the court. (1) Without Leave. GEROCHI V. Rule 31. Code of Civil Procedure section 2020. FRCP 5 (d) (1) (A). These are likely to be open-ended questions that may The meaning of INTERROGATORY is a formal question or inquiry; especially : a written question required to be answered under direction of a court. The trial court denied plaintiff's motion to compel on the ground that the questions "call for a legal theory of the facts [and] should be accomplished by means of written interrogatories wherein There are certain rules that accompany requests for admission, requests for production and interrogatories. Federal Rule 33 (b) (4) emphasizes that the “grounds for objecting to an interrogatory must be stated with specificity. If one party chooses to use an interrogatory, written questions Nov 15, 2023 · Depositions focus on gathering information and evidence from witnesses or parties involved in a lawsuit. Interrogatories are only exchanged between the actual parties in a lawsuit. (a) Any party may serve written interrogatories upon any other party. Each interrogatory must be answered separately and fully in writing under oath or affirmation, unless it is objected to. 2- deponent (party or not) is dead, 100 miles outside of the place for trial, can not attend because of sickness or age, cannot be found, is an expert or a skilled witness, even if available. (4) Within 14 days after the notice and written questions are served, a party may serve cross questions upon all other parties. In the last issue, the Legal Writer discussed the bill of particulars. Request for Production of Documents in an auto accident case. 1-510-797-9996 1-510-797-9998 (FAX) A deposition by written questions is an important part of your trial. 6 prevents an attorney from discussing the substance of deposition testimony with their witness while the deposition is ongoing. That eliminates the problem that counsel will prep the witness to your specific questions. Opposing lawyers want to guarantee a mutual understanding for ambiguous terms that can become muddled in the litigation process. Certiorari. Second, the order must be "in writing and must specify the time, place, manner, conditions, and scope of the examination and the person or persons by who it is to be made. To create your interrogatories, you will create a list of questions, label them “interrogatories” and include a letter that “demands” that the other side answer them. Interrogatories are written questions that ask the other party questions about the case. (a) (1) A party taking a deposition by written interrogatories shall serve a copy of the interrogatories upon each party or the attorney of record of each party. See Hoffman v. In law, interrogatories (also known as requests for further information) [1] are a formal set of written questions propounded by one litigant and required to be answered by an adversary in order to clarify matters of fact and help to determine in advance what facts will be presented at any trial in the case. Trial Lawyers. For further questions or more information on interrogatories, refer to the contact information below. #112, Fremont, CA 94538. For these reasons, interrogatories are sent early on in a case. Understanding these distinctions is crucial for individuals navigating legal matters. Because attorneys may help their clients answer interrogatories, interrogatory responses tend to be more finely (1) If depositions are to be taken and submitted on written interrogatories, the interrogatories shall be filed in triplicate with the application for deposition and served on the parties. After commencement of the action any party may take the testimony of any person, including a party, by deposition upon written questions. Code of Ala. Taking deposition or serving interrogatories in civil case as waiver of incompetency of witness, 23 A. Making requests for admission under FRCP 36. 1 Procedure for Noticing Deposition Upon Written Questions. e. Below is a sample set of plaintiff’s product liability interrogatories to the defendant. The plaintiff's attorney asked him essentially the same questions at deposition, and was met by an objection and refusal to answer. A party may, by written questions, depose any person, including a party, without leave of court except as provided in Rule 31(a)(2). For example, if you are unable to provide a document or answer an interrogatory question for any reason (such as it is written in a vague, objectionable, or irrelevant way) you may declare in your response why you are not able to answer This is when the parties seek information from each other that is relevant to the claims in the lawsuit. Similar to bills of particulars, interrogatories elicit detailed infor-mation about a case. 1(a). 2 (f) and the procedures in Rule 26. In addition, they both have the underlying goal of collecting information from the other party. By exchanging written questions and responses, both sides can gain a clearer understanding of the facts interrogatory. A copy of the interrogatories must be served upon all other parties to the litigation, in order to provide notice of the discovery requests. 1992); DeMasi v. , there is a distinction between possibility and probability. 200. There are many reasons to do a deposition live, versus on written question, including getting the person themselves, not just their attorneys answers. Apolinsky & Associates, LLC. In contrast to oral depositions, written depositions are less expensive since lawyers do not have to attend. 060(c)-(d)] No preface or instructions allowed [CCP §§ 2030. Because of the expense of depositions, they are not frequently used to gather information in a child custody case. IN THE UNITED STATES DISTRICT COURT. Interrogatories are open-ended written questions that solicit information about a case. Any ground not stated in a timely objection is waived unless the court, for good cause, excuses the failure. Written questions may be used in depositions as well. D. (deposition time limits in an action),12 199 (oral depositions),13 200 (depositions on written question),14 201 (depositions in foreign jurisdictions purpose of a deposition is for basic discovery, it is also utilized for the preservation of May a person take a deposition before an action is filed? See Rule 27. A private court reporter will make a record of the deposition. May 30, 2017 · During the discovery process, both spouses have the opportunity to ask questions, request documents, and conduct depositions to obtain evidence in support of their claims. You are required to respond to these interrogatories no later than thirty (30) calendar days after receipt of these Before a deposition on written questions is sent to the deponent, it must be sent to the other parties in the lawsuit. 05 | Persons Before Whom Depositions May Be Taken. A Rule 31 deposition is exactly like a Rule 30 deposition. Interrogatories can be used to discover information about the other party’s position, the facts of the case, and the evidence that the other party has. A party’s answers to interrogatories are often used in that party’s deposition. Within ten days after service, any party may file, in triplicate, with the Proceedings Clerk , his objections, if any, to such interrogatories and may file Interrogatories. In . The attendance of witnesses may be compelled by the use of subpoena as provided in rule 1. And even then, the dilatory party may file a motion to extend his time to answer. Interrogatories are written questions sent by one party to another to gather specific information about details of specific events, occurrences, and more. The location of all copies of each such document. Sample Car Accident Interrogatories. As an adjective interrogatory is serving to interrogate; questioning. Interrogatories are lists of questions sent to the other party that s/he must respond to in writing. A new lawyer’s guide to basic discovery rules. 150 East Ponce de Leon Avenue, Suite 200. Alternatively, an objection could be raised to the interrogatory with the goal of preventing the questioning. rrogatories if no person appears. 159796; APRIL 5, 2005. v. (E. CIV. Rule 57 | Interrogatories and Depositions. Sep 10, 2018 · Website. This happens when either party asks the other party or a potential witness to answer questions under oath. The receiving party then has to respond, truthfully and in writing, within a specified period of time (exactly how long can vary by state; in By means of demands for production of documents, written questions submitted (interrogatories and Requests for Admissions) and depositions (oral examination under oath before a reporter) the typical litigator in the United States will spend a hundred hours conducting discovery for every hour spent in the court room. NO. his deposition taken on written questions and denied defendant’s application to have him deposed on oral questions in New York County. Patricia Garcia. Dec 6, 2023 · As amended through December 6, 2023. 02 | Depositions Before Action or Pending Appeal. Jul 20, 2021 · Definitions. Relevance. Relevance is king in the kingdom of interrogatories. Here are some general characteristics of interrogatories to keep in mind: Interrogatories are written questions; The receiving party Interrogatories and depositions both occur during “discovery” and require responses under oath. (a) Notice of taking; service of questions and cross-questions. 1 Interrogatories are different from bills of particulars. Within 7 days after being 1- The deponent was an adverse party or an officer, director, or agent of adverse party or. 7, §§ 477-486. 3d 1109. Mandamus. Yet, that's precisely Dec 16, 2022 · 39159 Paseo Padre Pkwy. Instead, please provide all available information to answer the question. These requests might include: Interrogatories, which are written questions about things that are relevant or important to the case. Procedure on Depositions by Written Interrogatories. Form interrogatories are an easy way for parties to ask common questions by simply checking the boxes for the questions they wish to ask. Dec 16, 2020 · A deposition upon written questions may be taken of a public or private corporation or a partnership or association or governmental agency in accordance with the provisions of Rule 30(b)(6). A party may direct written interrogatories to any other party. (c) Answers and Objections. Jun 28, 2024 · Tex. State the name and address of any accountant, tax preparer, bookkeeper and other person, firm or entity who has kept or prepared books, documents and records with regard to your income, property, business or financial affairs during the course of this marriage. R. You or your spouse will have to provide written answers to the other’s interrogatories. Requirements and rules for interrogatories differ among jurisdictions. (a)Serving Questions; Notice. call: 404-377-9191. A response indicating lack of knowledge is only appropriate if you have absolutely no information on the question being Sep 11, 2023 · andthe judge may file cross-int. — Upon ex parte motion, any party desiring to elicit material and relevant facts from any adverse parties shall file and serve upon the latter written interrogatories to be answered by the party served or, if the party served is a public or private corporation or a partnership or association, by any Apr 30, 2021 · 1. ”. A party desiring to take the deposition of any person upon written questions shall serve such questions upon each party together with a notice stating the name and address of the person to be examined, if known, and, if the name is not known, a general description Overview. 710] Defined terms: Terms used in interrogatories may be given special definitions. Nov 11, 2020 · First, it applies Delaware Local Rule 30. , Tit. 04 | Depositions Upon Written Questions. Mar 30, 1970 · Notes of Advisory Committee on Rules—1970 Amendment. Phone. Notice of taking deposition on written questions. In many states, under that states rules of civil procedure, deposition by written questions can be done without leave of court. They are served by the opposing party who wants to obtain information from you. Interrogatories are written questions submitted by one spouse to the other. 1946) 9 Fed. The deponent's attendance may be compelled by subpoena under Rule 45. There are also rules for responding to and scheduling depositions. 3d 1089. (760) 891-5767. As amended through May 30, 2024. Interrogations aim to extract information related to a crime. A notice of intent to take the deposition must be served on the Contact a Personal Injury Attorney for Help. 06 | Presiding Officer For Deposition. Sep 10, 2018 · 10/9/18 Depositions vs interrogatories in Discovery . Confusion is created by the use of the same terminology to describe both the taking of a deposition upon “written interrogatories” pursuant to this rule and the serving of “written interrogatories” upon parties pursuant to Rule 33. Bloomberg Law offers a complete legal research solution for litigators, enhanced by the addition of 230 new Practical Guidance documents on our Discovery Resources Page. So long as that motion is heard within 30 days of filing, it too can stave off the 1. They can also be used to clarify any confusion or misunderstanding about the facts of Jan 8, 2021 · Interrogatories occur during the discovery process of a lawsuit. If the other side does not answer your interrogatories, you may be able to ask the judge to make the other side answer the questions by filing a motion to compel discovery. [6] [7] This caption should look exactly the same as the caption on every other document. Answers to interrogatories as limiting answering party's proof at state trial, 86 A. Except in a matrimonial action, a party may not serve written interrogatories on another party and also demand a bill of particulars of the same party pursuant to section 3041. And the procedures of Rule 33 are both simpler and broader than the previous statutory authorization, which they supersede, for interrogatories to an adverse party. B. Answers to interrogatories must be answered in what? Sample Product Liability Interrogatories. 22. Interrogatories are written questions that one party sends to another. You can demand the production of documents. Interrogatories are written questions for which written answers are Fundamentals of Discovery Practice: Interrogatories. Some sample probate interrogatories such as this one lays out key definitions beforehand that will be included in the Interrogatory Questions section ahead. 2 (g) and (h) for 2 days ago · What are interrogatories? Texas Rules of Civil Procedure 197 governs interrogatories. II. Rogovin, 3 AD3d 353 (1st Dept. 010 provides the methods a party may use to obtain information from a person who is not a party to the lawsuit. 33. Below are sample interrogatory questions propounded in a typical car accident lawsuit. The parties means the plaintiffs and defendants. Generally, interrogatories are objectionable if they seek information not within the scope of discovery defined Oct 18, 2023 · Perhaps the classic example of a discovery tool is a deposition. Saile, Jr. For example, if you are deposing a proof of death witness, then draft ques. You are a newly admitted lawyer and you’ve landed your first job helping your client obtain justice by fighting against the insurance companies. Wilson Line, Inc. Appendix offers Uniform Interrogatories and the jurisdictions that suggest or require they be used (including PA, NJ & DE) 1. A party may take the testimony of any person or entity by deposition on written questions before any person authorized by law to take depositions on written questions. Do not risk your settlement; give the Cordisco & Saile LLC a call today. Rule 31 is amended in parallel with Rules 30 and 33 to reflect the recognition of proportionality in Rule 26 (b) (1). Create your caption. Rule 33 (a) thus gives a party, in the case of original interrogatories, 75 days, and in the case of further answers, 60 days, to file answers before the guillotine can fall. Contact Cordisco & Saile for help with a deposition or interrogatory today: 215-642-2335. Feb 15, 2023 · They also help to identify subjects where additional discovery might be necessary. Section 1. P. In a limited civil case (cases less than $25,000, or $35,000 if filed after Jan. Get your documents served and filed to perfection - contact D&R Legal Process Service now. A carefully crafted set of interrogatories can obtain information that will lead to the use of other relevant discovery to Serving interrogatories under Federal Rule of Civil Procedure (FRCP) 33. The question should relate to the claims or defenses in your case. Interrogatory. A deposition on written questions is one in which the questioner submits written questions and an unrelated party, usually the court reporter, poses the questions as Those who must complete an interrogatory need to respond in writing and provide all discoverable information. See full list on justice4you. Considering that the Prosecution has already submitted their proposed questions in the written interrogatories, the accused, through counsel, is given a period of ten (10) days from receipt of this Resolution to submit their comment to the proposed questions on the deposition upon written interrogatories for the witness Mary Jane Veloso. There is no reason why interrogatories should be more limited than depositions, particularly when the former represent an inexpensive means of securing useful information. Dec 17, 2023 · 1. a party may serve on any other party interrogatories, subject to the numeric limits in Rule 26. The law considers anything ‘possible,’ but something is not probable unless it is more likel. Discovery Methods. [1] They can seek any of the information that is generally discoverable under Rule 26; that is, any information that is not privileged, relevant to any claim or defense and that is not an unreasonable burdensome request relative to the needs of the party. It is the duty of an attorney directing interrogatories to 2 days ago · Civil Practice Law & Rules Section 3131. CR 26 GENERAL PROVISIONS GOVERNING DISCOVERY. A34 Notice of Deposition Upon Written Questions Deposition by Written Questions vs Interrogatories: Understanding the Key Differences Deposition and interrogatories are two common methods used in legal proceedings to gather information and evidence from witnesses or involved parties. Within 30 days after the notice and written questions are served, a party may serve cross questions upon all other parties. Rule 213 - Written Interrogatories to Parties. Note also that interrogatories are available against any other party, not simply an adverse party. No party may serve more than a total of 50 interrogatories upon any other party unless permitted to do so by the court upon motion, notice and In answering these questions if you have any knowledge available to answer the question, a response indicating a lack of knowledge is not appropriate. 410. 2023 October. A deposition is a process in which you are sworn in before being asked questions by an attorney (who usually Jul 12, 2023 · Written discovery motions are the most cost-effective way to gather information in a child custody dispute. [2] Complainant, through her counsel, Snider and Fischer LLC, requests that the Agency respond to the following interrogatories. Interrogatories are written questions posed to the opposing party, for which a response is required, under conditions specified by the jurisdiction ’s rules of court procedure. What is the default maximum length of a In lang=en terms the difference between interrogatory and deposition is that interrogatory is a formal question submitted to opposing party to answer, generally governed by court rule while deposition is the process of taking sworn testimony out of court; the testimony so taken. A deposition is a meeting where oral questions are asked, while an interrogatory is a written series of questions. Written interrogatories, part of this new offering, are an essential element to your case no matter which side you represent. Civ. Local Rule 30. Because interrogatories are written, they lack spontaneity and aren’t well suited to situations where in-depth probing is required. Federal courts in California have held that there is a right to privacy that can be raised in response to discovery requests. A deposition is a sworn testimony by a party to the lawsuit or by any witness, recorded by an authorized court official. " TEX. Written Interrogatories 1. Interrogatories may require copies of such papers, documents or photographs as are relevant to the A. Sep 27, 2022 · Written Depositions. The person being deposed usually will come to the office of the attorney for the party requesting the deposition. Rule 1. They are written questions to the other party. Interrogatories Interrogatories can elicit information concerning the opposing party's discovery conduct that a less formal inquiry may not reveal. Depositions by Written Questions (a) When a Deposition May Be Taken. The rule specifically provides that the scope . Stephen D. Dismissal of state court action for failure or refusal of plaintiff to answer written interrogatories, 56 A. Through Oct 30, 2018 · It's not uncommon for attorneys seeking discovery to dismiss the utility of interrogatories in favor of depositions. Jan 20, 2020 · RULE 25 INTERROGATORIES TO PARTIES . DEPT. Noticing a deposition of a company designee under FRCP 30(b)(6). Thompson, 971 F. Weiss, 669 F. While interrogatories take the form of written questions, depositions are conducted (6) Where the deposition is to be taken on written interrogatories, the party taking the deposition shall serve a copy of the interrogatories, showing each interrogatory separately and consecutively numbered, on every other party with a notice stating the name and address of the person who is to answer them, and the name, description, title Jan 24, 2022 · Parties may obtain discovery by one of more of the following methods: depositions upon oral examination or written questions; written interrogatories; production of documents or things or permission to enter upon land or other property, for inspection and other purposes; physical and mental examinations; and requests for admission. 03 | Depositions Upon Oral Examination. com Nov 13, 2023 · A deposition upon written questions may be taken of a public or private corporation or a partnership or association or governmental agency in accordance with the provisions of Rule 30(b)(6). Sitting for a deposition or interrogatory can be an unnerving process and it is easy to make a mistake. Decatur, Georgia 30030. (2)Number. (a)Directing Interrogatories. Service of interrogatories can be done by mail or email, if the responding party has agreed to email service. When a party to a civil case needs to get information from the other side, she can serve the other side with written requests called “discovery requests. old an interviewer thatthat might seem tend the deposition. For example, “What is the agency’s formal explanation for terminating the complainant?” Committee Notes on Rules—2015 Amendment. The person deposed gives testimony and answers questions asked by the attorneys from both sides. The discovery rules limit the number of interrogatories but judges can allow more questions if there is a reason to do so. 514, Case 2; Brewster v. Objection: The Definition of “You” is Impermissibly Overbroad. Any other party may object to a question or request that additional (cross) questions be asked, serving the purpose of cross-examination. (Interrogatories do not require cross-questions because there will be other opportunities The field of inquiry will be as broad as the scope of examination under Rule 26(b). A copy of the interrogatories shall be served on all other parties entitled to notice. However, if your case is somewhat more complicated, you may want to consider it as an option for gathering information. Rogovin v. t. 57. You can use interrogatories to find out facts about a case but they Rule 3109. Johnson by Johnson v. OF ENERGY; G. Usually depositions consist of an oral examination, followed by cross-examination by the opposing side. May depositions be taken upon written questions? Though not listed on the assignments page, take a look at Rule 31. In civil procedure, an interrogatory is a list of written questions one party sends to another as part of the discovery process. Jun 13, 2023 · Both depositions and interrogatories are used to obtain information and evidence that can be used as proof in a trial, but there are some notable differences. If the answering party objects to any interrogatory, the party must state the reasons for the objection in lieu of an ntiffs’ attorney Bruce Fagel once. 320 - DEPOSITIONS UPON WRITTEN QUESTIONS. ” *CCP § 2030. Rules Serv. More Sample Interrogatories. 204. The defined terms must be Jan 1, 1997 · 33. (2) With Leave. 6] Standard Interrogatories Exchanging written interrogatories is the first discovery step utilized by attorneys to obtain information relating to the parties and the occurrence in question. 1, 2024) you may ask each party only 35 questions total, whether they are form interrogatories, special interrogatories, requests for admission, or requests for production of Drafting New York Civil-Litigation Documents: Part XI — Interrogatories. Interrogatories may, without leave of court, be served upon any party after service of the summons and complaint. Rule 33 - Interrogatories to Parties. In legal terms, interrogatories are formal written requests — in the form of questions — issued by a party in a lawsuit to another party. However, interrogatories and depositions have notable differences. 01 Availability. 21. (b)Duty of Attorney. What are Interrogatories. The recipient must answer in writing under oath and according to the case's schedule. Interrogatories vs. Interrogatories are written questions served by a party on another party. (a)Who may be noticed; when. R. 6 to FRCP 31 depositions, starting when the questions are received. In addition to taking depositions, either party may submit written questions, called interrogatories, to the other party and require that they be answered in writing under oath. (a)Generally. The top of the first page of your interrogatories must include the same caption that appears at the top of the first page of every document that has been filed with the court in your case. Aug 8, 2005 · depositions upon written questions. Message View Profile. Posted on Sep 10, 2018. Interrogatories may relate to any matters embraced in the disclosure requirement of section 3101 and the answers may be used to the same extent as the depositions of a party. 1-800-799-7233 (National Domestic Violence Hotline) Interrogatories are a discovery tool that the parties can use to have specific questions about a case answered before trial. The deponent, on deposition or on written interrogatory, shall ordinarily be required to answer all questions not subject to privilege or excused by the statute relating to depositions, and it is not grounds for refusal to answer a particular question that the testimony would be inadmissible at the trial if the testimony sought appears reasonably calculated to lead to the discovery of May 30, 2024 · PDF. Discovery can include interrogatories, requests for admissions, and requests for production. wers to8 tricky deposition questions1 The Impossible DreamIn la. You are required to answer these interrogatories separately and fully in writing, under oath. oc hr br ii pd sn ss el be qt