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Client FAQ's – Interrogatories

Laura Holt is a Paralegal at DHHW.  She joined Dragga, Hannon, Hessler, & Wills, LLP in 2014 and has worked with the firm as a Paralegal since 2015.

In a contested case, one portion of the case is dedicated to discovery.  Discovery is the gathering and exchange of information (for example facts, information, and documents) to understand each party’s position and develop evidence in the case.  One discovery tool often used are Interrogatories. Interrogatories are written questions to the opposing party that must be answered in writing and under oath. This means the answers must be truthful and accurate, as if the client is testifying in court.

Maryland Rules allow each party in a case to ask 30 Interrogatories of the other party. Once a party has been served with Interrogatories, he or she has 30 days to respond. Typically, Interrogatories cannot simply be answered with yes/no responses and usually require a good bit of time from the client to consider and draft the answers.

The attorneys and paralegals assist clients during the discovery phase of the case, including answering Interrogatories.  When sending the Interrogatories to the client, we try to make the process as easy as possible. Suggestions often include breaking up the questions into batches and providing us with each answer as written, and tips for how to correctly identify witnesses.

When we get draft answers from a client, we review them. Usually at this point, we set up a phone call with the client to discuss the draft answers and to fill in any missing gaps. Completing the Interrogatories may take a few phone calls and/or emails to make sure we understand the responses, can format them as required by the Maryland Rules, and provide complete and accurate answers. While answering Interrogatories may become overwhelming, the attorneys and paralegals are available to assist you with any questions and concerns throughout the entire discovery process, using our experience to ease the process.

Likewise, clients are obligated to supplement and update their answers to Interrogatories until the case concludes.  Supplements might include new information or information the client has since remembered.  We are available to assist our clients with these supplements.

We encourage our clients to reach out to the attorney(s) and paralegal assigned to their case with any questions they have about discovery, including Interrogatories and the client’s responses.

Contributors:  Laura Holt, Paralegal, and Lindsay Parvis, Esquire, Partner.

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