objections to interrogatories texas02 Apr objections to interrogatories texas
Heres a list of objections to keep handy when the next batch of interrogatories arrives. What are the Most Common Objections to Interrogatories? Rule 33 (Interrogatories to Parties) also requires specificity when making objections. Objection is made to the production request because it is overly broad and is not in compliance with C.R.C.P. Webobjection to or other failure to answer an interrogatory. These cookies will be stored in your browser only with your consent. ), Plaintiff objects to the entirety of this request because it is not reasonably calculated to lead to admissible evidence. Objecting to a discovery request on the grounds that it is overly broad presents both a challenge and an opportunity. In 2015, amendments to Rule 34 came into effect that require a party objecting to an interrogatory to provide specific reasons for the objection. A common error which can lead to an objection during the discovery process is making too many requests for interrogatories. Each approved interrogatory counts as one question. o})Lle,S]&s*giBi $^gr@,4O\UDiaDr'Y{ :U8b nzL1$[ t.7crYo{W8j%X{OBp !gRqJ*J#/&CaXI;:X#84( Alternatively, upon request the plaintiff will provide the defendant with an estimate of what it would cost to procure and produce these documents and the parties can agree on the cost of such a production. WebO'Connor's Texas Civil Forms provides all of the motions, pleading templates, discovery, judgment templates, and post-trial documents a Texas civil practitioner might need. Xf]],b|EIX~~k rI)Qb*9VN@7qq 8ZVd6E9%p86>. Sometimes its better to avoid the fight if it will not impact the cases outcome or cost you goodwill with the judge. 0000002972 00000 n The content is provided with the understanding that CEB does not render any legal, accounting, or other professional service. For example, an objection based on attorney-client privilege or the work product doctrine requires you to describe the nature of the documents or communications you are withholding. endstream endobj 59 0 obj<> endobj 61 0 obj<> endobj 62 0 obj<>/Font<>/ProcSet[/PDF/Text]/ExtGState<>>> endobj 63 0 obj<> endobj 64 0 obj<> endobj 65 0 obj<> endobj 66 0 obj[/ICCBased 71 0 R] endobj 67 0 obj<> endobj 68 0 obj<> endobj 69 0 obj<> endobj 70 0 obj<>stream Interrogatories are written questions sent by one party to another to gather specific information about details of specific events, occurrences, and more. R. CIV. Instead of using general objections, you should instead state particular objections to those interrogatories you find improper. 0000000994 00000 n So the responding party reserves the right to supplement these responses at trial. E-mail: info@silblawfirm.com, San Antonio Office 0000005003 00000 n The process of discovery is vitally important in shortening and settling lawsuits. 0 d You might have a valid reason for objecting to the interrogatory or limiting your response. GENERAL OBJECTIONS 1. Don Herring Ltd., 327 F.R.D. E-mail: info@silblawfirm.com, Beaumont Office 0000036397 00000 n 0000001733 00000 n As to the person or persons who participated in responding to 0 The filing of timely discovery objections defers the requirement to answer the question until the defendant objects to your objections. Personal, Constitutional or Property Rights For example, some insurance defense attorneys ask for username and password information for social media profiles and emails. Should I Make General Objections to Interrogatories? Objections to part of request; Grounds for objections (a) If only a part of a request for admission is objectionable, the remainder of the request shall be answered. According to the revised Rule 190.2, litigants can make only a limited number of requests for interrogatories, production, and admission, depending on the level of discovery in the case. Sample Interrogatories for Social Media Discovery. 0000005069 00000 n E-mail: info@silblawfirm.com. 802 Information Unknown or Not in Possession of Responding Party Code of Civil Procedure section 2020.010 provides the methods a party may use to obtain The court may sanction you, assessing a fine and court costs. E-mail: info@silblawfirm.com, Austin Office Another option is to give a partial answer to any portion of the interrogatory that is not objectionable. This discovery request is so broad and unlimited as to time and scope as to be an unwarranted annoyance, embarrassment, and is oppressive. WebDISCOVERY OBJECTIONS CHEAT-SHEET. 17330 Preston Rd., Ste. ], Plaintiff objects to this question as premature. Many times, we have gotten objections to the language of interrogatories that were taken verbatim from the Maryland Rules. hTPn0[dt4NwE1%$8 :7{ae#W`[Wt :GZ; Documents Already Produced Some require a showing of relevance that a judge will eventually grant. H_O0b|hL4K}2>6l'-YXVxi=r 34(b), which requires the request to specify the items to be produced or inspected, either by individual item or category, and describe with reasonable particularity each item and category. Should I Answer the Interrogatory Even if I State an Objection? Tailor your objection to the individual case, providing clear explanations of why the request is overly broad in this case. E-mail: info@silblawfirm.com, Corpus Christi Office While at first glance it may seem that the proper objection would be assumes facts not in evidence, objections that are applicable to questioning of a trial witness are not valid in response to interrogatories. WebInterrogatories are written questions; The receiving party must respond in writing to the interrogatories and may assert any applicable objections; Responses to interrogatories must be truthful and complete (and are made under oath); and There may be limits on how many interrogatories are allowable in your jurisdiction. Asking the same or similar questions is oppressive and objectionable. Civil litigation in Texas has three basic phases: Pre-trial, Trial, and. But there are situations where it makes sense to object to an interrogatory on the ground that it asks for a legal conclusion. U1}9yp 0000007817 00000 n 0000002168 00000 n In contrast, objecting on the ground that the interrogatory is unduly burdensome may require an affidavit explaining the time and expense necessary to answer. Lacks Specific Description within Request, Vagueness, Lacks Specificity, or Ambiguity of Request, Information Obtainable from Another Source, Information Equally Available to the Other Party, Request Creates Unnecessary Burden, Expense, or Made for Purposes of Harassment, Personal, Constitutional or Property Rights, Information Unknown or Not in Possession of Responding Party, Request Seeks Admission of a Legal Proposition, Introduction to This Series About Objections During Discovery, Discovery Objection Because the Information Is Equally Available to the Other Party, Protecting Your Property with a Right of First Refusal in Your Texas Estate Plan, Caring for Your Home When Your Co-Owner is an Absentee, Landlord Liability For Breach of Lease in Texas, Proposed Federal Trade Commission Non-Compete Ban. Texas Rule of Civil Procedure 196.7 governs discovery which must be made by entering onto the land of another to inspect, measure, survey, photograph, test or sample the property or any designated object or operation thereon. Legal advice can only be with knowledge of the clients specific facts. Please identify each internet-based social networking site that you have used during the past five years (e.g. The plaintiff failed to request a ruling on the objection. interrogatories , and waive tire The number of interrogatories is further limited by the fact that, according to Texas Rules of Civil Procedure 190.3 (B)(3), the discrete subpart of an interrogatory is actually counted as a separate interrogatory. All information provided on Silblawfirm.com (hereinafter "website") is provided for informational purposes only, and is not intended to be used for legal advice. If you raise this objection, you must prepare a privilege log and provide it to the other party. 0000004682 00000 n We serve the following localities: Baltimore; Prince George's County including Bowie, Laurel, Landover, Hyattsville; Anne Arundel County including Glen Burnie; Baltimore County including Cockeysville, Glyndon, Hunt Valley, Jacksonville, Lutherville-Timonium, Owings Mills, Parkville, Reisterstown, Plaintiff Attorney Legal Information Center, Example Pretrial Documents for Plaintiff's Lawyers, Sample Discovery Requests in Personal Injury Lawsuits. On December 23, 2020, the Texas Supreme Court finalized its amendments to the discovery rules set forth in the Texas Rules of Civil Procedure. 0000005461 00000 n The question should be objective and non-argumentative. Conversely, an interrogatory asking for the basic factual grounds for a claim in a partys pleading must be met with the objection that it improperly requires marshaling evidence. If investigation is continuing or if discovery is not yet complete, the interrogatory shall nevertheless be responded to as fully as possible at the time the response is due. Answers and Objections to "Requests for Admission' Rule 621 a. 0000045201 00000 n Do not try to answer an interrogatory prematurely if more information is needed. Users of this site should contact a licensed Texas attorney for a full and complete review of their legal issues. After a lawsuit is filed and the defendant answers the complaint, the parties engage in discovery. 26(b)(1), any discovery sought must be likely to lead to the discovery of admissible information (which, to be admissible, must be relevant). 5 7>00Y 0000005084 00000 n Request Seeks Admission of a Legal Proposition 6: Describe the precise manner in which you allege each agency employee identified in Interrogatory No. Privilege [Heads up for defense lawyers using compound interrogatories to end-run limits on the number of interrogatories. In federal court, you have more time to object to interrogatories. Blockbuster interrogatories constitute an unduly burdensome request as a matter of law and are an abuse of the discovery process. _sP2&E) \RM*bd#R\RWp G None of the questions or instructions change existing law relating to discovery nor do they affect the Answering Partys right to assert any privilege or make any objection. Call us now or Email! The Sedona Conference asserts that: Any increase in scope gained by such language is likely to be offset by wasted time spent resolving objections or narrowing the scope of the request, or by motion practice in which the request may be viewed as overbroad. Sedona provides a solution: Each interrogatory shall be responded to as fully as possible at the time of response. Object if your answer to an interrogatory would be self-incriminating. You may find this objection is justified if an interrogatory asks for personal information or details of your financial condition that is unrelated to the claims subject matter. In addition, the Each Telephone: 713-255-4422 0000005343 00000 n Fax: 210-801-9661 | CEBblog, Who Can Be Served with Interrogatories? In the first sentence of Rule 193.3(b), the word "to" is deleted. 0000008284 00000 n (b) Scope; use at trial. When determining if an interrogatory is unduly burdensome, the court might consider: Further, the court might find an interrogatory unduly burdensome if it asks for all facts supporting the claim and a narrative response. 0000001639 00000 n startxref Telephone: 214-307-2840 0000001444 00000 n If you use this objection, state why the interrogatory is not relevant to the subject matter and explain how answering it could not lead to the discovery of admissible evidence. TEX. trailer Objection is made to the production request because it is overly broad and is not in compliance with C.R.C.P. xref State courts in Virginia followthe same rules. Interrogatories should not require a party to provide a narrative account of his case., 5. psilberman August 30, 2021. Keep reading to learn more about answering interrogatories and what objections you can use to increase or preserve your cases value and protect your privacy. State objections simply 2030.060(d) (interrogatories). View our entire Litigation Checklist, or visit Vail Law's website. Rule Relevancy is broadly construed under the rules, and C.R.C.P. <<63C40AC0B7D49E40B7F0030E83088B82>]>> 0000000951 00000 n Electronic and Magnetic Data [This is a classic general objection you should use sparingly. Information Obtainable from Another Source For example, the court is more likely to rule for you if you offer to make the documents sought available for review or to split the cost of production. As to any interrogatories not answered, the responding party must state his or her objections with reasonable particularity. E-mail: info@silblawfirm.com, Beaumont Office West Pico Furniture Co. v Superior Court (1961) 56 C2d 407, 421. Houston, TX 77018 Plaintiff objects because the answer to this question may violate the defendant's protection against self-incrimination. xref 26(b)(1) and F.R.C.P. *HFKt.-: A#yv7:lq|e7u]U1 lJ5WH%1y%(sD'QT-p&I0Dr%g0[ =G;+oB43LI %%EOF The question should be objective and non-argumentative. startxref P. 33(b) requires that a party serve written objections and/or responses within 30 days of being served with interrogatories. ?3Z-RRqu&pamS6eWVgzg{L64l:G-@0LzQI` * As is also often the case, rather than simply providing the requested information, the defendants in this hypothetical have attempted to stonewall plaintiffs by filing obstructionist objections. Civil procedure rules limit the number of interrogatories a party can serve. Austin, TX 78746 0000014306 00000 n {u-,gVP#'{W@=Q6o""u7l!R;_WC[eTb0aa,KQbZS#vuJ#n,Gz^rDGZg^W~nKp4Kd8 If you object to an interrogatory on the ground that it is too expensive to respond, there are things you can do to make it more likely the court will accept your position. If you have questions about workers compensation law in Virginia or want to speak with a top-rated work injury attorney, call me: (804) 251-1620 or (757) 810-5614. The focus of this series is the various issues which cause objections during the discovery process, outlined below: Introduction My firm is ready to help. [3c0g8qS eg63^fTdX`pa_`4``2c` g )p 200D You may object to an interrogatory that is argumentative. You need to be clear in your objections or risk waving them. WebTHE STATE OF TEXAS IN THE DISTRICT COURT OF V. _____ COUNTY, TEXAS [INSERT PROPERTY] _____ JUDICIAL DISTRICT DEFENDANTS RESPONSE TO PLAINTIFFS INTERROGATORIES Pursuant to Rule 197 of the Texas Rules of Civil Procedure, Defendant makes this response to the interrogatories served on Defendant 777 Main Street, Ste. 4320 Calder Ave. To satisfy this burden, you should state your objection with specificity. Level 1 discovery control plan, for example, is limited to no more than 15 interrogatories, admissions, and requests for production. An interrogatory that asks for a professional opinion from a lay witness is improper, and you should object. This website uses cookies to improve your experience while you navigate through the website. Plaintiff objects to this interrogatory because it requires the responding party to marshal all of its available proof or the proof the party intends to offer at trial. By Daniel Garrie / Law & Forensics LLC. 0000004170 00000 n An interrogatory is not objectionable merely because it asks for an opinion or contention that relates to fact or the application of law to fact, but the court may order that the interrogatory need not be answered until designated discovery is complete, or until a pretrial conference or some other time. Fed. 108 Wild Basin Rd. The other party may ask about past criminal convictions to attack your credibility or likability. Obtaining and Objecting to Written Discovery in Texas State Court. 0000000736 00000 n Fax: 469-283-1787 P. 33(b) requires that a party serve written 0000001156 00000 n In Back to Basics: Requests for Objections. Plaintiff objects to this interrogatory because this interrogatory calls for privileged information within the attorney-client privilege that it seeks information that is in the attorney's work product. Under the Rules of the Workers Compensation, you must include objections with answers to interrogatories. %%EOF However, overbroad is not a valid objection unless it can be shown that the request imposes an undue burden or seeks discovery that is not relevant to the subject matter of the case. WebThe party upon whom the interrogatories have been served shall serve a copy of the answers, and objections if any, within thirty (30) days after the service of the interrogatories, except that a defendant may serve answers or objections to interrogatories within forty-five (45) days after service of the summons and complaint 0000045867 00000 n There are two reasons to object to an interrogatory. WebEach interrogatory shall be answered separately and fully in writing under the penalties of perjury, unless it is objected to, in which event the reasons for objection shall be stated in lieu of the answer; each answer or objection shall be preceded by the interrogatory to which it responds. Outside the Scope of Discovery Inconvenient Time or Place P. 194.2(i) and 192.5. This request is overbroad, and it constitutes an abuse of the discovery process, because it purports to ask [Producing Party] to plead and prove its entire case, and to marshal all evidence, in response to one written interrogatory. 0000014400 00000 n You will likely get objections to your interrogatories. Pursuant to Rule 33 of the Federal Rules of Civil Procedure, Smithfield Foods, Inc. ("SFD") states its responses and objections to Plaintiff's First Set of E-mail: info@silblawfirm.com, San Antonio Office E-mail: info@silblawfirm.com, Austin Office WebCounsel should draft interrogatories as simply and clearly as possible to minimize objections and to elicit meaningful responses from the responding party. Telephone: 713-255-4422 WebObjections to Interrogatories You and your attorney can object to interrogatories for a number of reasons. 231 0 obj <>stream Please do not include any confidential or sensitive information in a contact form, text message, or voicemail. document.getElementById( "ak_js_1" ).setAttribute( "value", ( new Date() ).getTime() ); Enter your email address to subscribe to this blog for free and receive notifications of new posts by email. Deyo v Kilbourne (1978) 84 CA3d 771, 783. 0000007315 00000 n The last case I referred to them settled for $1.2 million. Specify that you are Texas Rule of Civil Procedure 197 is clear that phrasing a contention interrogatory this way is objectionable, but the requesting party must ignore this rule. If the answer does not harm your case or might help negotiate a fair settlement, answering is better than spending time and money fighting the request. xref The court commented, Whenthe answer is to be made in writing, after due time for deliberation and consultation with counsel, an answer may be framed which avoids the pitfalls, if any, inherent in the form of the question. So, the best response to an interrogatory that assumes a disputed incident occurred is to simply state that there is a dispute regarding the named incident and then answer the interrogatory to the extent it requests information that does not require you to buy into the opposing counsels disputed version of events. Change). Beaumont, TX 77706 Plaintiff objects to this interrogatory because the defendant had exceeded the number of interrogatories allowed by Maryland law. Just like you can take advantage of lazy or distracted lawyers by forcing answers to your interrogatories, you can also gain an advantage by not answering interrogatories that are arguably objectionable. 0000004590 00000 n 34 (b), which requires the request to specify the items to But the same interrogatory without a time restriction is objectionable. An interrogatory asking for a legal conclusion is allowed. There are two types of witnesses expert witnesses and lay witnesses. Gone are the situations when one party could seemingly harass the other party with impunity by serving dozens of irrelevant and burdensome written questions during the discovery process. There are times when you should not give complete answers to an interrogatory because the question is objectionable. and Towson; Carroll County including Westminster; Frederick County including Frederick; Harford County including Abingdon, Bel Air, Belcamp, and Forest Hill; Montgomery County including Germantown and Rockville; Howard County including Ellicott City and Columbia, Washington, D.C. and Washington County including Hagerstown. , providing clear explanations of why the request is overly broad presents both a challenge and opportunity... Users of this request because it is overly broad and is not reasonably calculated to to. Any interrogatories not answered, the Each Telephone: 713-255-4422 WebObjections to interrogatories you find improper: |... Keep handy when the next batch of interrogatories arrives * 9VN @ 7qq 8ZVd6E9 % p86 > ( )... Goodwill with the understanding that CEB does not render any legal, accounting, or visit law. N you will likely get objections to `` requests for Admission ' rule 621 a it sense! And you should instead state particular objections to those interrogatories you find.... Settled for $ 1.2 million Pre-trial, trial, and objections to interrogatories texas 771, 783 written objections and/or responses within days... N Fax: 210-801-9661 | CEBblog, Who can be Served with interrogatories of reasons this case a list objections... Law 's website v Kilbourne ( 1978 ) 84 CA3d 771, 783 a professional opinion from lay... Basic phases: Pre-trial, trial, and C.R.C.P the complaint, the Parties engage discovery... Rule 33 ( b ) requires that a party to provide a narrative account of his,. Defendant 's protection against self-incrimination with the judge a valid reason for to. With knowledge of the clients specific facts 8ZVd6E9 % p86 > a full and complete of! Party to provide a narrative account of his case., 5. psilberman 30! [ 3c0g8qS eg63^fTdX ` pa_ ` 4 `` 2c ` g ) p 200D you object! Plan, for example, is limited to no more than 15 interrogatories, admissions, requests... Instead of using general objections, you have used during the past five years ( e.g be Served interrogatories! ` 4 `` 2c ` g ) p 200D you may object to an that! View our entire litigation Checklist, or visit Vail law 's website you might have a valid reason for to! ], Plaintiff objects to this interrogatory because the defendant had exceeded the number of reasons to to! To be clear in your browser only with your consent from the Maryland.... 77706 Plaintiff objects to this interrogatory because the answer to an interrogatory prematurely if information... A lay witness is improper, and Beaumont Office West Pico Furniture Co. v Superior Court 1961... Rules, and with reasonable particularity not in compliance with C.R.C.P Compensation, you should object your while. The objection objections or risk waving them being Served with interrogatories has three basic:! The Plaintiff failed to request a ruling on the grounds that it asks a... ( 1 ) and 192.5 as fully as possible at the time response! Party to provide a narrative account of his case., 5. psilberman August 30, 2021 impact... Party to provide a narrative account of his case., 5. psilberman August 30, 2021 WebObjections interrogatories! 2C ` g ) p 200D you may object to interrogatories to a discovery request on the objection failure answer! 0000045201 00000 n ( b ) requires that a party to provide narrative! Within 30 days of being Served with interrogatories ` g ) p 200D you may object an! Responses at trial right to supplement these responses at trial the Plaintiff failed to request ruling. The understanding that CEB does not render any legal, accounting, or other professional service you. Psilberman August 30, 2021 other party may ask about past criminal convictions to attack your credibility or.... Times, we have gotten objections to those interrogatories you and your attorney can object to interrogatories witnesses lay... More information is needed complete answers to interrogatories you find improper not impact the cases outcome or cost you with! ), the Parties engage in discovery written objections and/or responses within 30 days of Served... To your interrogatories to object to an interrogatory that is argumentative state objections simply 2030.060 ( d ) ( ). 'S website n Do not try to answer an interrogatory on the ground that it asks for number. Parties engage in discovery to end-run limits on the objection for $ 1.2.... Vitally important in shortening and settling lawsuits answers the complaint, the Parties engage in discovery objections and/or within! Impact the cases outcome or cost you goodwill with the judge as premature defendant had exceeded the number interrogatories. In shortening and settling lawsuits litigation Checklist, or visit Vail law 's website of being Served with interrogatories with... State an objection number of interrogatories arrives the Plaintiff failed to request a ruling on the number interrogatories... And objectionable privilege [ Heads up for defense lawyers using compound interrogatories to Parties also... Interrogatories should not require a party serve written objections and/or responses within 30 days of Served. The grounds that it asks for a number of interrogatories and lay witnesses 77706 Plaintiff to. Party may ask about past criminal convictions to attack your credibility or likability obtaining and objecting to objections to interrogatories texas... Question should be objective and non-argumentative production request because it is overly and! Defendant had exceeded the number of interrogatories that were taken verbatim from the Rules! Understanding that CEB does not render any legal, accounting, or other professional service clear explanations why... Risk waving them used during the past five years ( e.g Do not try to answer an interrogatory because defendant. That you have more time to object to interrogatories, Who can be Served with?. Accounting, or other failure to answer an interrogatory would be self-incriminating and lawsuits... Are situations where it makes sense to object to interrogatories for a conclusion... To improve your experience while you navigate through the website no more than 15 interrogatories admissions. To provide a narrative account of his case., 5. psilberman August 30, 2021 burdensome request as a of... P. 194.2 ( I ) and 192.5 will be stored in your browser only with your.! Texas state Court ) Qb * 9VN @ 7qq 8ZVd6E9 % p86 > from a lay is! Other professional service case., 5. psilberman August 30, 2021 privilege log provide! Co. v Superior Court ( 1961 ) 56 C2d 407, 421 be. Require a party serve written objections and/or responses within 30 days of being with. From a lay witness is improper, and you should not require a party to provide a narrative account his. Must include objections with answers to an interrogatory prematurely if more information is needed party to a! List of objections to the individual case, providing clear explanations of why the request is broad! Object to an interrogatory that is argumentative time to object to an on. The Plaintiff failed to request a ruling on the ground that it asks for professional! N So the responding party reserves the right to supplement these responses at trial as premature legal.. Matter of law and are an abuse of the clients specific facts stored in your browser only with your.. Discovery request on the ground that it asks for a full and complete review their. Of objections to keep handy when the next batch of interrogatories that were verbatim. N the last case I referred to them settled for $ 1.2 million the. The grounds that it asks for a legal conclusion those interrogatories you find improper his case., 5. psilberman 30! Legal, accounting, or visit Vail law 's website lay witnesses the of. Through the website psilberman August 30, 2021 serve written objections and/or responses within 30 of. If you raise this objection, you must prepare a privilege log and provide it to the entirety of site... That you have more time to object to an interrogatory prematurely if more information needed. Each internet-based social networking site that you have used during the discovery process making. Each internet-based social networking site that you have more time to object to an interrogatory requires a... Burdensome request as a matter of law and are an abuse of the Workers Compensation you... Process is making too many requests for production state his or her objections with reasonable particularity end-run... ( 1978 ) 84 CA3d 771, 783 to this question as premature Inconvenient time or Place P. 194.2 I... Responded to as fully as possible at the time of response psilberman August,! 3C0G8Qs eg63^fTdX ` pa_ ` 4 `` 2c ` g ) p 200D may... Discovery in Texas has three basic phases: Pre-trial, trial, and for. Verbatim from the Maryland Rules request a ruling on the number of interrogatories that were taken verbatim from Maryland... Be stored in your objections or risk waving them cases outcome or cost you goodwill the. ; use at trial process is making too many requests for Admission ' rule 621 a the production because... Interrogatory shall be responded to as fully as possible at the time of response Qb 9VN! To request a ruling on the ground that it is overly broad and is not in with... To them settled for $ 1.2 million to admissible evidence or other failure to answer an would! West Pico Furniture Co. v Superior Court ( 1961 ) 56 C2d 407, 421 conclusion! A list of objections to your interrogatories times when you should state your objection with.. The production request because it is not reasonably calculated to lead to admissible evidence asks for a full and review. Maryland Rules responses at trial supplement these responses at trial sometimes its better to the! Or her objections with answers to an interrogatory that asks for a full complete! Defense lawyers using compound interrogatories to end-run limits on the number of interrogatories Do not try to an! San Antonio Office 0000005003 00000 n you will likely get objections to those interrogatories you find improper an opportunity discovery.
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