Learn what to do if you have received written discovery requests from the other side. These might include requests to produce documents, or to answer written questions (called “interrogatories”), or to admit or deny certain facts (called “request for admissions”).
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.” These requests might include:
Interrogatories, which are written questions about things that are relevant or important to the case. (NRCP 33; JCRCP 33)
Requests for production of documents or things, which are written requests that demand the other side provide particular documents or items. (NRCP 34; JCRCP 34.)
Requests for admissions, which are written requests that ask the other side to admit or deny certain facts about the case. (NRCP 36; JCRCP 36.)
If you have received discovery requests (which would probably come in the mail), you have thirty days to mail your written responses back to the other side. Missing that thirty-day deadline can be serious. It could even result in you losing the case.
To learn how to respond to discovery requests you have received, click to jump down to one of these sections:
How to respond to requests for production of documents
How to respond to requests for admissions
TIP! You may need to talk to a lawyer about the requests you received or do some legal research – especially if your case is complex! This website doesn’t cover every aspect of discovery. It doesn’t talk in detail about how you might be able to object to certain discovery requests or protect certain information. It also doesn’t talk about depositions or what you might need to do if you’ve received a notice requiring you to appear for one. Click to visit Lawyers and Legal Help or Researching the Law.
“Interrogatories” are written questions to the other side. Each party to a case can typically serve forty interrogatories to the other side, unless the judge has set some other number.
If you have received interrogatories, you have thirty days to prepare your written answers (unless the court has ordered something else). You do not file your written answers with the court. You simply mail the original back to the other side. If you do not mail your answers back within thirty days, the court could sanction you.
Make sure you keep a copy of your answers for your records.
Here are some things to remember when preparing your answers to interrogatories:
You must retype each of the interrogatories, and then follow each interrogatory with your answer. Like this:
INTERROGATORY NO. 1: What is the year, make, and model of your automobile?
ANSWER NO. 1: I own a 1995 Chevy Camaro.
INTERROGATORY NO. 2: What is the license plate number of your automobile?
ANSWER NO. 2: My license plate number is BNA642.
If you are unable to answer an interrogatory because it is too vague, ambiguous, or somehow objectionable, you can state an objection and the reason for your objection. You must then answer to the extent the interrogatory is not objectionable. For example:
INTERROGATORY NO. 3: Please describe your automobile.
ANSWER NO. 3: I object that this interrogatory is vague. Without waiving this objection and to the extent I understand this question, my car is red and in good condition.
TIP! Objections can be tricky and complicated! You may want to do some research at your local law library or consult with an attorney if you think you need to assert objections. Click to visit Lawyers and Legal Help or Researching the Law.
Your interrogatory answers must be “verified,” meaning you must sign the verification page included with the form below in front of a notary and swear that your answers are true. You must mail the original verification page with the interrogatories back to the other side.
Your answers to the interrogatories should usually be short, clear, and direct and should answer only the question that is being asked. This is not the time to set out your entire case or defense to the other side.
Take the time to make sure your answers are correct and truthful. You will be signing them under penalty of perjury. Any false or incomplete statements could be punished by the court. They could also end up losing you the case.
You can download a form to help you prepare your Answers to Interrogatories by clicking one of the formats underneath the form’s title below: