Interrogatories

Interrogatories — easy to draft poorly, hard to draft well — get a focused chapter covering advantages and disadvantages, parties, timing, subject-matter scope (primary and objective information, opinions and contentions), interrogatory format, drafting techniques and the limits on number, objection practice, and answer preparation including the duty to investigate, qualified responses, and the ethical limits on disclosure. The chapter also addresses business-records and ESI responses under Rule 33(d), supplementation, and use of responses at trial. Best fit as a unit reading in a pretrial litigation course, the chapter gives professors a complete scaffold for an interrogatory-drafting and response exercise that tests both doctrinal knowledge and practical judgment.