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What are Interrogatories? How Do I Respond to Them?

What Are Interrogatories in a Legal Context?

Interrogatories are formal written questions that one party in a lawsuit can serve upon another party to obtain specific information relevant to the case. They are part of the discovery process and are governed by specific rules and regulations. In New York law, they are ruled by N.Y. CPLR § 3130, the full text of which is below.

Are Interrogatories Just Regular Questions?

In the legal context, interrogatories are not the same as everyday questions you might ask in a casual conversation. Instead, they are formal written questions posed by one party to another during the "discovery" phase of litigation. Unlike casual queries, interrogatories are designed to obtain specific and factual information relevant to the case. The receiving party must provide written answers under oath, ensuring the accuracy and honesty of the responses. 

10 Tips to Respond to Interrogatories?

  1. Read Carefully: Begin by thoroughly reviewing the interrogatories to understand the questions being asked fully.
  2. Consult an Attorney: Before responding, consult with your legal counsel to determine the most appropriate answers.
  3. Answer Truthfully: Provide honest and accurate information in all your responses.
  4. Be Concise and Clear: Offer direct answers to the questions, avoiding any unnecessary elaboration.
  5. Raise Objections: If a question seems irrelevant, overly broad, or inappropriate, consider objecting to it. Consult with your attorney regarding the grounds and validity of such objections.
  6. Protect Privileged Information: Avoid disclosing information that may be protected by attorney-client privilege, work-product doctrine, or other legal protections.
  7. Organize Your Responses: Number your answers to correspond with the interrogatory numbers, ensuring clarity and coherence.
  8. Request Clarifications: If a question is vague or ambiguous, ask the opposing counsel for a clearer or more specific interrogatory.
  9. Document Everything: Keep a copy of the interrogatories and your responses for your records.
  10. Meet Deadlines: Interrogatories usually come with a specified deadline. Ensure you respond within this timeframe to avoid potential legal consequences.

If you need help answering interrogatories, complete this intake form.

What Are 10 Examples of Common Objections to Interrogatories?

  1. Overbroad or unduly burdensome.
  2. Vague or ambiguous.
  3. Irrelevant or not reasonably calculated to lead to admissible evidence.
  4. Calls for legal conclusions.
  5. Privileged information.
  6. Seeks work product.
  7. Already answered or readily available.
  8. Calls for speculation.
  9. Compound question.
  10. Invasion of privacy.

How Do I Formally Object to A Question?

Under NY CPLR § 3130, to formally object to an interrogatory, you provide a written response specifying the grounds for your objection, typically within the time frame designated for answers. Consult legal counsel for proper phrasing and procedure.

On What Grounds Can I Raise an Objection to An Interrogatory?

Under NY CPLR § 3130, objections to interrogatories can be raised if the questions are irrelevant, overly broad, unduly burdensome, or seek privileged information.

What Happens If I Provide False Information in My Response?

Under NY CPLR § 3130, providing false information in an interrogatory response can result in sanctions or penalties. Providing accurate and truthful information is crucial to maintain credibility in a civil case.

Sample Interrogatories

CIVIL COURT OF THE CITY OF NEW YORK                                                                                COUNTY OF QUEENS

ABC Debt Purchasers, LLC,                                Index No.: 12345/2023

Jane Doe,


  1. Please state your full name, current address, and date of birth.

  2. Confirm whether you had a credit account with XYZ Credit Card Company, and if so, provide the account number.

  3. List all payments you made towards the account from the date of inception to the present, including the date, amount, and method of payment.

  4. Identify any disputes you raised concerning this account, the nature of the dispute, and the outcome or resolution, if any.

  5. Have you ever reported the loss or theft of a credit card associated with the account in question? If so, please provide the date and circumstances of such report.

  6. Please list all communications you received from the original creditor, XYZ Credit Card Company, regarding the alleged debt.

  7. Identify any other person or entity that you authorized to use the credit account in question.

  8. Describe any and all instances where you believe you were charged fees, interest, or other charges that you did not authorize or that were not in accordance with your agreement with the original creditor.

  9. Please provide copies of any correspondence or communication you had with XYZ Credit Card Company or any other entity concerning the alleged debt.

  10. Identify any defenses, set-offs, or counterclaims you intend to assert in response to this lawsuit.

Sample Responses to Interrogatories

CIVIL COURT OF THE CITY OF NEW YORK                                                                                COUNTY OF QUEENS

ABC Debt Purchasers, LLC,                           Index No.:  12345/2023


Jane Doe,


  1. Response: My full name is Jane Doe, my current address is 123 Maple Street, Queens, NY 11111, and my date of birth is January 1, 1985.

  2. Response: I do not recall having a credit account with XYZ Credit Card Company. Please provide documentation or proof of such an account bearing my name.

  3. Response: Without admitting the existence of said account, to the best of my recollection, I have not made any payments to XYZ Credit Card Company.

  4. Response: I have never raised any disputes concerning an account with XYZ Credit Card Company as I do not recall having such an account.

  5. Response: I have not reported the loss or theft of any credit card associated with XYZ Credit Card Company.

  6. Response: To my knowledge, I have not received any communications from XYZ Credit Card Company regarding an alleged debt.

  7. Response: I have never authorized any other person or entity to use a credit account with XYZ Credit Card Company.

  8. Response: As I do not recall having an account with XYZ Credit Card Company, I cannot provide instances of unauthorized charges.

  9. Response: I have not had any correspondence or communication with XYZ Credit Card Company or any other entity concerning an alleged debt.

  10. Response: I reserve the right to assert defenses, set-offs, or counterclaims as deemed appropriate after reviewing the evidence and consulting with my legal counsel.

What should I Do when I receive interrogatories in a consumer debt case?

When you're served with interrogatories in a consumer debt case, taking the right steps ensures that you navigate the process effectively. Here are three primary actions you should consider:

  • Consult an Attorney: Before attempting to answer any questions, seek guidance from a lawyer familiar with consumer debt. They can clarify, ensure your responses are accurate, and advise on potential objections.
  • Review and Respond: Carefully read each question and gather any pertinent documents that can aid in your responses. Be truthful in your answers, avoiding speculation. Always be mindful of the stipulated deadline, ensuring you respond promptly.
  • Document Everything: Maintain a record of the interrogatories received, the answers provided, and any related correspondence. This documentation can be crucial for reference as your case progresses.

By following these steps, you'll ensure that you approach the situation methodically, safeguarding your rights and interests.

What Rights Do I Have When Responding to Interrogatories?

When faced with interrogatories, knowing your rights is essential to ensure you respond appropriately and protect your interests. Here are three key rights you possess:

  • Right to Object: If you believe a question is irrelevant, overly broad, or seeks privileged information, you have the right to object. Your attorney can guide you on legitimate grounds for objections.
  • Right to Truthfulness: While you must answer truthfully, you aren't required to guess or speculate. If you don't know the answer or can't recall specific details, you have the right to state that in your response.
  • Right to Legal Counsel: You have the right to consult with an attorney before answering any interrogatories. An attorney can provide valuable insights, ensure your responses are compliant, and advocate on your behalf.

Knowing and exercising these rights can ensure you navigate the interrogatory process effectively while safeguarding your interests.

Is There a Deadline to Answer Interrogatories in New York?

In New York, as with many legal processes, specific timelines are associated with responding to interrogatories. Here's what you need to know, especially in reference to NY CPLR 3130:

  • Standard Timeframe in NY: Under NY CPLR 3130, a party may serve written interrogatories upon another party after the commencement of an action. Typically, the recipient has 30 days from the date of service to respond.
  • Extensions and Adjustments: If you need more time, you may be able to request an extension. It's advisable to make this request well before the initial 30-day period expires to ensure timely compliance and avoid potential legal repercussions.
  • Potential Consequences: Failing to answer interrogatories within the set timeframe, or as adjusted by any extensions, can lead to penalties and might adversely affect the outcome of your case.

Given the importance of timely responses in the legal process, it's crucial to be aware of NY-specific rules and to ensure that all responses adhere to the stipulated deadlines.

How Important Is It to Understand Each Interrogatory Question in New York?

Interrogatories are a vital part of the legal discovery process, and fully comprehending each question is crucial, especially in New York, where the legal system has its nuances. Here are three reasons why understanding every interrogatory question is of paramount importance:

  • Accuracy of Responses: To provide truthful and accurate answers, it's essential first to understand what's being asked. Misinterpreting a question can lead to incorrect or incomplete answers, potentially harming your case or leading to penalties.
  • Strategic Legal Positioning: Grasping the intent behind each question can help you and your attorney strategize. Some questions may be aimed at uncovering specific information or setting a trap for inconsistency. Understanding the nuances can aid in crafting responses that protect your interests.
  • Adherence to New York's Legal Standards: In the New York legal framework, certain stipulations dictate how parties should respond to interrogatories. A clear comprehension ensures that your responses align with these standards, avoiding potential complications or objections from the opposing party.

In essence, taking the time to understand each interrogatory question isn't just a good practice—it's vital for ensuring a favorable outcome in your legal proceedings.

In Consumer Debt Cases, What Types of Questions Are Asked in Interrogatories in New York?

In consumer debt cases in New York, the questions are tailored to understanding the debtor's financial situation, the legitimacy of the debt, and any relevant communications or actions. Here are three general categories of questions you might encounter:

  • Financial Details: Questions in this category aim to understand the debtor's financial status. This can include inquiries about income sources, assets, bank accounts, properties, and other financial holdings. There might also be queries about monthly expenses, existing financial obligations, and any recent large transactions.
  • Verification of the Debt: The interrogating party might ask questions confirming the debt's existence, amount, and legitimacy. This can include details about the original creditor, the nature of the debt (e.g., credit card, loan), the outstanding amount, and the history of payments or defaults.
  • Communication and Actions: Interrogatories may also probe into past communications between the debtor and the creditor or collection agency. Questions could address any disputes over the debt, attempts at resolution, or any agreements (written or verbal) that might have been made.

Being prepared for these types of questions can help you craft accurate and strategic responses, especially when working with legal counsel familiar with New York's consumer debt laws.

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Why Are Interrogatories Used in Consumer Debt Lawsuits?

In the realm of New York's consumer debt lawsuits, interrogatories play a pivotal role. Here's why:

  • Evidence Gathering: Interrogatories allow the parties to gather crucial evidence that may not be readily available elsewhere. By posing specific questions, a party can obtain details about the debtor's financial situation, the validity of the debt, or other relevant matters.
  • Clarifying Facts: As legal proceedings can be mired in ambiguity, interrogatories serve as a tool to clarify facts. They can help narrow down the issues, identify discrepancies in the parties' narratives, and reduce the likelihood of surprises during the trial.
  • Strategy Formation: The answers to interrogatories can significantly influence the legal strategies of both the debtor and the creditor. For instance, if a debtor's responses highlight inconsistencies in the creditor's claim, the debtor might be in a stronger position to negotiate a settlement or even challenge the lawsuit's legitimacy.
  • Cost and Time Efficiency: Resolving ambiguities before the trial can expedite the legal process, making it more streamlined and potentially less costly for both parties.

Should I Provide More Information Than What’s Asked in The Interrogatory?

Under NY CPLR § 3130, answering interrogatories fully and accurately is advisable. However, providing unnecessary or unsolicited information can be counterproductive in a civil case.

What Are Supplementary Interrogatories and How Do I Handle Them?

Supplementary interrogatories are follow-up questions after initial interrogatories. Under NY CPLR § 3130, respond in writing within the designated time frame, ensuring accuracy and consistency with prior answers. Seek legal guidance for specific situations.

Are Supplementary Interrogatories Different from Initial Ones?

Yes, supplementary interrogatories are follow-up questions post the initial set. They address new or expanded issues and ensure comprehensive information gathering in a legal case.

Why Are Interrogatories Crucial in The Discovery Phase?

The discovery phase of litigation is a pivotal period where parties gather information, evidence, and insights to build or defend their case. Interrogatories, as a cornerstone of this phase, serve distinct and essential functions. Let's explore further.

How Do Interrogatories Help in Gathering Evidence?

Interrogatories are designed to solicit detailed and specific information from the opposing party. Their structured format helps in the following:

  • Precision: Unlike oral questioning, where a witness might evade or provide vague answers, written interrogatories require clear and direct responses. This ensures a higher degree of accuracy.
  • Documentation: Since responses are written and under oath, they create a record that can be introduced as evidence in court.
  • Comprehensiveness: Interrogatories can cover a wide range of topics, from factual details to the identification of witnesses or evidence. This provides a more holistic view of the opponent's perspective and evidence.

Can interrogatories shape the strategy of a lawsuit?

Absolutely. Interrogatories play a significant role in determining the direction and approach of litigation. Here's how:

  • Identifying Strengths and Weaknesses: The responses to interrogatories can reveal vulnerabilities in the opposing party's case or affirm the strengths of one's own. This allows legal teams to adapt and fortify their strategies accordingly.
  • Aid in Settlement Negotiations: Knowledge gained from interrogatories can guide parties in determining the feasibility of settlements or compromises. If one side realizes their position is weaker than initially thought, they might be more inclined to settle.
  • Preparation for Depositions or Trial: Knowing the opposing party's answers in advance can be a powerful tool in preparing for further oral depositions or the trial itself. Lawyers can anticipate arguments and prepare counterarguments, leading to a more robust case presentation.

What Are Common Reactions to Receiving Interrogatories?

Upon being served with interrogatories, individuals often have varied reactions depending on their familiarity with the legal process. Here are three typical responses:

  • Anxiety and Overwhelm: For many, receiving formal legal questions can be daunting, especially if they're unfamiliar with the legal process. Concerns about how to answer correctly and the potential consequences of their responses can be sources of stress.
  • Avoidance or Procrastination: Some individuals might set the interrogatories aside, thinking they have ample time to respond. Delaying can sometimes result from not knowing how to approach the questions or hoping the issue might somehow resolve itself.
  • Seeking Guidance: Those who have some awareness of the implications of interrogatories often seek advice. Whether turning to the internet for initial research or directly consulting with an attorney, they seek guidance on how to approach the situation properly.

Understanding these common reactions can help address the situation more effectively and alleviate associated concerns.

Why Should I Consult with an Attorney Before Responding to Interrogatories in New York?

Responding to interrogatories can have significant implications for your legal case, especially within New York's complex legal landscape. Consulting with an attorney before crafting your responses is a prudent decision, and here are three key reasons why:

  • Expert Guidance: An attorney will have in-depth knowledge of the law and can guide you on how best to answer each question. They can also identify potential pitfalls, ensuring you don't inadvertently provide information that could be detrimental to your case.
  • Strategic Response: Beyond understanding the questions, a seasoned attorney can help you draft answers that align with your legal strategy. This includes what information to provide and how to phrase responses in a way that best represents your interests.
  • Protection from Overreach: Sometimes, interrogatories might contain questions that are overly broad, irrelevant, or violate your rights. An attorney can help you recognize and object to such questions, ensuring you only provide information that's legally required.

The Full Text of CPLR § 3130:

§ 3130. Use of interrogatories

1. Except as otherwise provided herein, after commencement of an action, any party may serve upon any other party written interrogatories. Except in a matrimonial action, a party may not serve written interrogatories on another party and also demand a bill of particulars of the same party pursuant to section 3041. In the case of an action to recover damages for personal injury, injury to property or wrongful death predicated solely on a cause or causes of action for negligence, a party shall not be permitted to serve interrogatories on and conduct a deposition of the same party pursuant to rule 3107 without leave of court.

2. After the commencement of a matrimonial action or proceeding, upon motion brought by either party, upon such notice to the other party and to the non-party from whom financial disclosure is sought, and given in such manner as the court shall direct, the court may order a non-party to respond under oath to written interrogatories limited to furnishing financial information concerning a party, and further provided such information is both reasonable and necessary in the prosecution or the defense of such matrimonial action or proceeding.


In simple terms, CPLR § 3130 tells you that:

  1. In most legal cases, after a lawsuit has started, the parties involved can send each other written questions (called interrogatories) that must be answered under oath.
  2. There are some exceptions to this rule, such as in divorce cases, where you can't send both interrogatories and a request for a bill of particulars to the same party.
  3. In cases involving personal injury, property damage, or wrongful death based only on negligence, you need the court's permission to send interrogatories to a party and also take their deposition (oral testimony under oath).
  4. In divorce cases, the court can order people who are not directly involved in the case to answer written questions about the finances of one of the parties, if the information is necessary and reasonable for the case.

Seven Attributes of CPLR § 3130 As outlined in the Statute's Practice Commentaries:

  1. Interrogatories are written questions sent by one party to another, answered under oath, and returned by mail.
  2. They differ from depositions, which require an in-person appearance and a verbatim recording by a stenographer.
  3. Interrogatories are less probing than oral depositions because answers are carefully formulated with the help of counsel.
  4. There is no priority rule for interrogatories before or after other discovery devices.
  5. Interrogatories are especially useful in commercial cases and when a corporation is a party.
  6. Interrogatories can only be used against parties, not nonparty witnesses.
  7. The interrogatory has a restricted scope in negligence cases in New York practice.

In the intricate world of New York's legal system, having an attorney's guidance when responding to interrogatories can make the difference between a favorable and unfavorable outcome.

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