MASTER THE ART OF CRAFTING EFFECTIVE INTERROGATORIES:
Save Time And Effort With Our Sample Interrogatories
Save Time And Effort With Our Primary Set Of Sample Interrogatories.
In personal injury litigation, effective discovery is crucial to building a strong case and achieving the best outcome for your clients. Interrogatories, governed by O.C.G.A. §9-11-33, are an essential tool in the discovery process, allowing attorneys to gather critical information from opposing parties. An “interrogatory” is a series of written questions sent by any party in a civil suit to the other party.
The Role Of Interrogatories In Georgia Car Accident Lawsuits:
Information is a crucial asset in legal proceedings. Interrogatories typically consist of open-ended questions that ask a party to describe facts, claims, or details about the case. These are not multiple-choice questions. Responses to these questions can assist in gaining insight into a party’s mindset and case strategy. However, it is important to note that answers from interrogatories are not admissible as evidence in court until they are tendered during the trial.
Interrogatory Limits & Timeframes In Georgia:
Pursuant to O.C.G.A. §9-11-33(a)(1), Georgia law allows each party to submit up to 50 interrogatories, including subparts. It's advisable not to send all 50 interrogatories at once. Instead, start by sending Georgia Trial Attorneys’ request for admissions, first interrogatories and first request for production of documents. Upon receiving responses to these pleadings, you'll be better positioned to craft targeted second interrogatories that yield better results for your client. Parties have 30 days to respond to interrogatories or raise objections; failing to respond in time results in waived objections and necessitates providing complete answers.
To help our fellow personal injury attorneys streamline their discovery efforts, Georgia Trial Attorneys has compiled a library of sample interrogatories, tailored to a motor vehicle or car accident case. To access our free Sample Interrogatories for car accident lawsuits, simply click the link below, provide your name and email address, and we will email you the template:
IN THE STATE COURT OF HALL COUNTY STATE OF GEORGIA
PLAINTIFF’S FIRST INTERROGATORIES TO DEFENDANT ROBERT SMITH
TO: Robert Smith, Defendant.
FROM: John Smith
Plaintiff, John Smith, by their attorneys, James M. Grant and Georgia Trial Attorneys at Kirchen & Grant, LLC, hereby propounds Interrogatories upon the Defendant, Robert Smith, to answer fully, within 30 days of service of these Interrogatories, under oath, and in accordance with O.C.G.A. §9-11-33 & §9-11-26 subject to the instructions set forth below:
1. These Interrogatories are continuing in character as to require you to file supplementary answers if you obtain further or different information when such information becomes known or identified. O.C.G.A. § 9-11-26(e).
2. Unless otherwise stated, these Interrogatories refer to the time, place, and circumstances of the occurrence mentioned or complained of in the Complaint. The terms “car crash” refers to the same.
3. Where knowledge or information in possession of a party is requested, such request includes knowledge of the party's agents, agents directing this defense on the Defendant’s behalf, representatives, and unless privileged. When answer is made by corporate defendant, state the name, address and title of persons supplying the information and making the affidavit, and announce the source of his or her information. For all information withheld subject to a bona fide claim of privilege, a privilege log is required to be produced in accordance with Rule 5.5.
4. The pronoun “you” refers to the party to whom the Interrogatories are addressed and the parties mentioned in clause (c) above.
5. "Identify" when referring to an individual, corporation, or other entity shall mean to set forth the name and telephone number, and if a corporation or other entity, its principal place of business, or if an individual, the present or last known home address, his or her job title or titles, by whom employed and address of the place of employment. If such information is not known, provide information sufficient to locate said person. A party must furnish the names and addresses of witnesses known to the party or to the party’s attorney or other agents acting on a party’s behalf; this information is not part of the work product. Jaynes v. Blake, 119 Ga. App. 748 (1969).
6. The term “car crash” is defined as the incident occurring on Saturday, June 5, 2021 between the parties in this action.
7. Boilerplate and general objections to discovery is strongly discouraged by the Court. You must expressly make an objection and describe the thing not produced and reason the information was withheld.
8. Pursuant to O.C.G.A. §9-11-33(b)(2), an interrogatory is not objectionable “merely because an answer to the interrogatory involves an opinion or contention that relates to fact or to the application of law to fact.” Contention interrogatories that seek to clarify the basis for or scope of an adversary’s legal claim are permissible and an answer required.
1.Identification. Identify yourself by providing your full name, home addresses for the past ten years with times of residence, your employer and job title for the past 10 years with times of employment, date of birth and last four of your social security number.
2.Knowledge. Identify – by providing full name, current contact information, basis or topic of knowledge - any person with knowledge or involvement in the issues or events raised in any pleading in this matter; including but not limited to, the Complaint, any Answer, and any other
For more resources and sample documents, explore our comprehensive library, which includes our popular Sample Auto Accident Complaint for Magistrate Court.
We hope our template complaint proves to be a valuable asset in your personal injury practice. If you have any questions or need additional support, don't hesitate to reach out to our experienced team at Georgia Trial Attorneys. Together, we can deliver the best possible outcomes for our clients while upholding the highest standards of personal injury law.