Keep this checklist handy the next time you’re propounding or responding to interrogatories—whether it’s your first time or you’re so familiar with the procedures that you just might accidentally skip something. PROPOUNDING PARTY __ Decide whether to use interrogatories __ Draft and serve set of written interrogatories If specially prepared interrogatories exceed 35: __ Attach declaration for additional discovery __ Retain originals of sets and responses RESPONDING PARTY Serve responses and objections: __ Determine time for service of response __ Forward interrogatories to client for response or information for use in drafting responses __ Draft responses and objections __ Return responses to client for review __ Obtain client verification to responses If protective order needed: __ Make reasonable, good faith attempt to resolve informally…
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