Plaintiff Attorney Legal Information CenterSample Answers to Interrogatories in a Product Defect Lawsuit
Below are sample answers to interrogatories in a product defect case against Walt Disney. Our client sustained a catastrophic brain injury after an alleged equipment failure during a theatrical production. These interrogatory responses are drawn from an actual case and reflect a strategic but cooperative approach to civil discovery. The names and details have been changed for obvious reasons.
We make only a few objections to these interrogatories because most of the inquiries are very reasonable. If you are facing interrogatories that are unreasonable, we provide a comprehensive list of interrogatory objections.
Whether you are seeking a sample response to a discovery request, a sample response to form interrogatories, or need help understanding how to prepare a legally sufficient answer to interrogatories, the examples below will help guide your process. These discovery responses cover a wide range of topics, including expert witness disclosures, economic damages, and permanent injury claims, particularly useful in personal injury interrogatory answers and complex product liability cases.
If you are unsure how to answer interrogatories in your case, or want a reliable response to an interrogatories sample that reflects the realities of modern litigation, these examples offer a practical and strategic starting point.
IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND
Civil Division
RICHARD DAVIS,
Plaintiff,
v.
DISNEY THEATRICAL PRODUCTIONS LTD d/b/a DISNEY THEATRICAL GROUP, et al.,
Defendants.
Case No. 24-C-18-007147
PLAINTIFF’S ANSWERS TO DEFENDANT’S INTERROGATORIES
TO: BUENA VISTA THEATRICAL GROUP, LTD., Defendant
FROM: RICHARD DAVIS, Plaintiff
Now comes the Plaintiff, Richard Davis, by and through his attorneys, Laura G. Zois and Miller & Zois, LLC, and hereby answers Interrogatories propounded upon him by Defendant Hyland Foundation, Inc., as follows:
- The information supplied in these Answers is not based solely on the knowledge of the executing party, but includes the party’s agents, representatives and attorneys unless privileged.
- The word usage and sentence structure is that of the attorney and does not purport to be the exact language of the executing party.
ANSWERS
INTERROGATORY NO. 1: State your full name, address, date of birth, marital status, and social security number.
ANSWER NO. 1: Richard Murray Davis; 540 Park Avenue, White Hall, Maryland 21161; January 28, 1990; single; 210-61-8096.
INTERROGATORY NO. 2: Give a detailed statement of all facts upon which you rely to show that each defendant was negligent.
ANSWER NO. 2: Plaintiff refers the Defendant to his Complaint and Amended Complaint and incorporates that pleading into these answers.
INTERROGATORY NO. 3: State the full name and last known address of every person known to you or your attorneys who were eyewitnesses to all the occurrence referred to in the complaint and state their location at the time thereof.
ANSWER NO. 3: Based upon information and belief, Barry Bruch 410-297-6249; David Frey, 1590 Robinson Road, Severna Park, MD, 410-975-5702; Dave Mattel 410-499-1658; and Mike Pollack 443-662-2099.
INTERROGATORY NO. 4: State the full name and last known address of every person known to you or to your attorneys who arrived at the scene of the occurrence within two (2) hours of the happening of the occurrence.
ANSWER NO. 4: Plaintiff is unaware of who arrived at the scene of the occurrence within the two hours of the happening of the occurrence other than those individuals listed in Plaintiff’s Answer No. 3, and local government emergency personnel.
INTERROGATORY NO. 5: State the full name and last known address of every person known to you or to your attorneys who has any knowledge of the facts and circumstances surrounding the happening of the occurrence referred to in the complaint.
ANSWER NO. 5: Kelly Clark (girlfriend); David and Joanne Clark (parents of girlfriend); Michelle and Mike Davidson, (friends); Megan and Kevin Glass (friends and neighbors); Mark Hutton (friend and neighbor); Bernie Trump (friend) and are expected to testify as to Plaintiff’s condition prior to the accident; pain and suffering following the accident; and how his activities of daily life changed after the accident.
INTERROGATORY NO. 6: Identify by name and address every expert that you expect to call as witnesses at trial and state the subject matter about which the expert is expected to testify, the substance of the findings and opinions about which the expert is expected to testify, and a summary of the grounds for each opinion.
ANSWER NO. 6
-
ANSWER NO. 6:
Plaintiff identifies the following expert witnesses whom he may call to testify at trial. These individuals are expected to offer opinion testimony based on their professional expertise, personal evaluation and treatment of the Plaintiff, and their review of the relevant medical records and diagnostic imaging. The list is subject to revision as new information becomes available.
Dr. Angela Marston, M.D.
Department of Trauma Surgery
Baltimore Trauma Institute
22 South Greene Street, Baltimore, MD 21201
(410) 328-5000
Field: Trauma and Emergency SurgeryDr. Marston is expected to testify regarding her role in leading the trauma team that received Mr. Davis at the University of Maryland Shock Trauma Center on September 5, 2023. She will testify to the nature and severity of the initial head trauma, including the depressed skull fracture, bilateral epidural hematomas, and pneumocephalus. Dr. Marston will explain how the injury patterns were consistent with a high-velocity blunt-force impact and how immediate neurosurgical intervention was necessary to preserve life. She will also testify that the injuries were causally related to the subject incident and were not attributable to any pre-existing condition. Dr. Marston’s opinions are based on clinical examination, operative records, and her experience treating traumatic brain injuries.
Dr. Joseph A. Levinson, M.D.
Baltimore Neuroimaging Group
7300 York Road, Towson, MD 21204
(443) 781-6400
Field: Diagnostic Radiology and NeuroimagingDr. Levinson interpreted multiple CT scans and MRIs of Mr. Davis’s head and brain. He is expected to testify about imaging findings showing bilateral frontal lobe contusions, cerebral edema, and a left parietotemporal skull fracture extending into the orbital apex. Dr. Levinson will explain that these findings are strongly correlated with cognitive and motor deficits, and that the pattern of injury indicates rotational and compressive forces consistent with a collapse of a heavy object. He will testify that the imaging supports the diagnosis of permanent neurologic injury and that future deterioration, including the risk of post-traumatic epilepsy, cannot be ruled out.
Dr. Sonal Patel, M.D.
Center for Neurocognitive Recovery
4500 Wilkens Avenue, Baltimore, MD 21229
(410) 857-2040
Field: Physical Medicine and RehabilitationDr. Patel has overseen Mr. Davis’s neurorehabilitation since his discharge from inpatient trauma care. She will testify to his physical and cognitive deficits, including executive function impairment, gait abnormalities, and severe fatigue. Dr. Patel will describe the structure of Mr. Davis’s rehab plan and outline the trajectory of recovery. She will further testify that Mr. Davis is unlikely to return to competitive employment and will require lifelong accommodations, assistive technology, and periodic re-evaluation. Dr. Patel’s opinion is based on longitudinal functional assessments, occupational therapy records, and her direct patient interaction.
Dr. Edward T. Glass, M.D.
Bay State Neurosurgery & Spine
1919 Maryland Avenue, Suite 202, Baltimore, MD 21218
(410) 936-0210
Field: NeurosurgeryDr. Glass performed the craniotomy to relieve intracranial pressure and evacuate the hematomas. He will testify to the extent of cerebral trauma discovered during surgery, including cortical bruising and vascular damage. Dr. Glass will explain that the left-sided brain injury affects language and spatial processing and that Mr. Davis now meets criteria for post-traumatic brain injury syndrome. He will further testify to the likelihood of long-term cognitive deficits, reduced IQ, and potential need for a future ventriculoperitoneal shunt. His opinions are grounded in intraoperative findings and follow-up neurological evaluations.
Dr. Marjorie Heller, Ph.D.
Cognitive Neuropsychology Associates
205 N. Charles Street, Baltimore, MD 21201
(410) 624-8800
Field: NeuropsychologyDr. Heller administered comprehensive neuropsychological testing to Mr. Davis approximately eight months post-injury. She is expected to testify to significant deficits in attention, short-term memory, processing speed, and emotional regulation. She diagnosed Mr. Davis with moderate to severe neurocognitive disorder due to traumatic brain injury. She will explain how these deficits prevent independent living and preclude gainful employment. Her findings support a permanent partial disability classification. Her opinion is based on validated clinical testing batteries and correlation with medical imaging.
Dr. Carl D. Everett, M.D.
Mid-Atlantic Orthopedics
10210 Reisterstown Road, Owings Mills, MD 21117
(443) 867-4222
Field: Orthopedic SurgeryDr. Everett treated Mr. Davis for left ankle fractures and joint instability. He performed open reduction and internal fixation (ORIF) of the medial and posterior malleolus and will testify that Mr. Davis now exhibits post-traumatic arthritis, chronic pain, and decreased weight-bearing tolerance. Dr. Everett anticipates that the Plaintiff will eventually require ankle fusion or replacement surgery and that the injury results in a permanent loss of mobility and balance. Dr. Everett’s testimony will also relate to the overall loss of quality of life and the compounding effect of lower extremity disability in a patient with cognitive impairment.
Dr. Karen M. Raye, M.D.
Maryland Pain Institute
1818 Belvedere Boulevard, Baltimore, MD 21215
(410) 765-2323
Field: Pain Management and NeurologyDr. Raye has treated Mr. Davis for chronic post-concussive headaches, cervicalgia, and jaw pain following the incident. She will testify that the Plaintiff’s pain is neurogenic and likely permanent. Treatment has included pharmacologic pain management, occipital nerve blocks, and trigger point injections. She will also testify to the psychological overlay of chronic pain and the need for coordinated mental health and pain management services going forward.
Dr. Allan Rousseau, Ph.D.
Rousseau Safety Consulting
3920 Falls Road, Suite 303, Baltimore, MD 21211
(443) 821-9383
Field: Theatre Safety & Rigging EngineeringDr. Rousseau is a retained expert in stagecraft safety and theatre rigging systems. He is expected to testify that the rolling set cart in question was defectively designed and failed to meet industry standards for equipment used in confined backstage spaces. Specifically, he will testify that the locking mechanism was undersized, the center of gravity was too high, and the absence of adequate warning labels or visual hazard indicators constituted a significant safety hazard. His opinions are based on ANSI Entertainment Technology standards, field measurements of exemplar carts, and review of incident photos and blueprints.
Dr. Nina Barkley, Ph.D.
Human Factors & Ergonomics Consulting
1200 Potomac Avenue, Silver Spring, MD 20910
(301) 555-8912
Field: Human Factors EngineeringDr. Barkley is expected to testify that the placement, handling instructions, and physical configuration of the set cart created a foreseeable risk of injury to individuals in the work area. She will testify that the design did not account for expected user behavior, failed to provide redundancy against tip-over hazards, and violated basic principles of human-centered design. She will also opine on cognitive load and visibility issues affecting workers during load-out operations. Her findings are based on ergonomic models, load force calculations, and industry best practices.
Dr. Lena B. Greene, CPA, MBA
Greene Forensic Consulting
7300 Light Street, Suite 200, Baltimore, MD 21230
(410) 840-0123
Field: Forensic Economics & Vocational LossDr. Greene will calculate the full extent of Mr. Davis’s economic loss, including past and future lost wages, future loss of earning capacity, fringe benefits, and cost of care. She will present alternate scenarios using varying rates of inflation and life expectancy projections. Based on Mr. Davis’s projected trajectory in the stage production industry and expert medical findings, Dr. Greene will offer a conservative present-value calculation exceeding $2 million in future economic damages.
INTERROGATORY NO. 7: State with precision the nature and location of bodily injuries suffered by you as a result of the occurrence.
ANSWER NO. 7: As a direct result of the occurrence, the Plaintiff sustained a depressed parietal skull fracture with pneumocephalus, bilateral epidural hematomas, a left hemothorax, left fourth and fifth rib fractures, right first and second rib fractures, a left lateral maxillary sinus wall fracture, a left parietotemporal skull fracture extending into the left orbital apex, a left parasymphyseal and right subcondylar mandibular fracture, left ankle medial and posterior malleolus fractures, which injuries required three subsequent surgeries. Plaintiff contends his injuries are permanent in nature.
INTERROGATORY NO. 8: If you have any complaints on account of injuries received as a result of the occurrence, state in detail the nature of such present complaints.
ANSWER NO. 8: Plaintiff continues to suffer from headaches, weakness, and chronic pain in his jaw, head, neck, back, and left ankle. The Plaintiff generally has limited endurance, difficulty sleeping, and emotional distress. Ankle: problems with walking, standing, and ankle swelling; difficulty with balance; arthritic changes have set in and are accelerated. At night, the Plaintiff experiences cramps and spasms. Jaw: ongoing pain, numbness, difficulty chewing, occasional choking, and difficulty with speech. Head: Headaches, vision issues, memory lapses, difficulty concentrating.
INTERROGATORY NO. 9: State which of your injuries, if any, you contend are permanent.
ANSWER NO. 9: Plaintiff contends the injuries to his head, ankle, and jaw are all permanent.
INTERROGATORY NO. 10: Identify all hospitals, physicians, health care providers and any other persons or institutions who have rendered treatment to you as a result of the occurrence for which this suit has been brought providing their full names and addresses and state the dates and nature of such treatments.
ANSWER NO. 10: Plaintiff refers Defendant to his medical records and bills attached to his Responses to Defendant’s Requests for Production of Documents, incorporated herein by reference, for the details of his medical treatment.
INTERROGATORY NO. 11: Itemize all expenses, loss of earnings or earning capacity, and other economic damages, past and future, that you claim are a result of the occurrence and as to each item claimed identify the item, the amount claimed for that item, the method, if any, by which you computed the amount, the figures used in that computation, and the facts and assumptions upon which your claim is based.
ANSWER NO. 11
| PROVIDER | DATES OF SERVICE | TOTAL | |
|---|---|---|---|
| 1 | City of Baltimore Ambulance | 09/05/2023 | 410.00 |
| 2 | UMMS | 09/05/2023 – 09/11/2023 | 83,188.83 |
| 3 | University Physicians | 09/05/2023 – 09/27/2024 | 28,554.00 |
| 4 | C.R.N.A. | 09/05/2023; 09/06/2023 | 1,491.00 |
| 5 | Anesthesia Associates | 09/06/2023 | Will supplement |
| 6 | Shock Trauma Associates | 09/05/2023 | Will supplement |
| 7 | Kernan Hospital | 09/13/2023 – 09/27/2023 | 15,607.24 |
| 8 | Diagnostic Imaging Specialist, PA | 12/22/2023 – 01/04/2024 | 418.00 |
| 9 | Advanced Radiology | 10/28/2023 | 88.00 |
| 10 | Lab Corp | 10/28/2023 | 48.00 |
| 11 | An Invitation To Heal | 11/03/2023 – 02/09/2024 | 5,800.00 |
| 12 | Kernan Hospital CLINIC | 11/17/2023 | 221.54 |
| 13 | Kevin Williams, DDS | 11/30/2023 – 01/09/2024 | 767.00 |
| 14 | Maryland Orthotics & Prosthetics | 01/23/2023 | 493.63 |
| 15 | Leroy Spodak, MD, PA | 01/31/2024 – 08/22/2024 | 2,092.00 |
| 16 | UMMS | 10/03/2023 – 03/08/2024 | 4,529.36 |
| MEDICAL EXPENSES TO DATE: | $143,708.60 | ||
| Mike’s Family Markets | 178 days, 8 hour days @ $10.25/hr | $14,956.00 | |
| Stage Hand, Etc. | $50,000/year × 40 years | $2,000,000 |
Plaintiff claims these costs in economic damages and reserves the right to supplement this response as discovery is ongoing, his treatment is ongoing, and Plaintiff is not in possession of all the medical records and bills. Additionally, the plaintiff claims pain and suffering in the past as well as pain and suffering in the future, past medical bills, future medical bills, future loss of earning capacity, and past lost wages. Plaintiff may require a future ankle fusion.
[Editor’s note: This new case, albeit unreported, that came in late 2020 has led to a change in practice on the specificity of our expert designations in state court.]INTERROGATORY NO. 12: State whether prior to or subsequent to the occurrence, you have sustained any accidental injury for which you received medical care or treatment. If so, describe the date and circumstances of the accidental injury and identify all healthcare providers, including hospitals and other institutions, that furnished care to you.
ANSWER NO. 12: Plaintiff objects to this interrogatory as the information sought is irrelevant, and the discovery of which is not likely to lead to information that would be admissible at trial. Furthermore, the probative value is outweighed by the prejudicial effect; however, without waiving said objections, Plaintiff had a boating accident in or around 2020 where he suffered a broken left wrist. He had a full recovery.
INTERROGATORY NO. 13: If you have ever had any serious illness, sickness, disease, or surgical operation, either prior or subsequent to the occurrence referred to in the complaint, state the date and place when and where this occurred and set forth a detailed description of your symptoms, the names and addresses of all physicians, surgeons, osteopaths, chiropractors, medical practitioners and hospitals rendering treatment, the approximate date of your recovery or if you did not recover fully, the date you achieved maximum recovery and/or disability and a description of your condition at that time.
ANSWER NO. 13: Plaintiff incorporates by reference herein his Answer to Interrogatory No. 12; and further states that he has not had any serious illness, sickness, disease, or surgical operation, subsequent to the occurrence that is unrelated to the occurrence.
INTERROGATORY NO. 14: If you contend that a previous injury or condition was aggravated by the occurrence for which this suit has been brought, describe such previous injury or condition, and give the names and addresses of all persons or institutions who treated or examined you for the previous injury or condition and the approximate dates of such treatments or examinations.
ANSWER NO. 14: Plaintiff makes no such contention. However, Plaintiff anticipates an expert to be hired by the defense to say that he had degenerative conditions that pre-existed the accident. In anticipation of this defense, Plaintiff reserves the right to argue that any pre-existing condition that he may have had before the accident was aggravated by the accident with the Defendant and that the pre-existing condition made him more susceptible to injury. Any pre-existing condition that the Plaintiff may have had before the date of the accident was asymptomatic.
INTERROGATORY NO. 15: If you were an insured (or beneficiary) under any policy of insurance under which you received benefits or reimbursement for medical expenses or any other losses resulting from the occurrence referred to in the Complaint, state the name and address of the company paying the benefits and whether the company required you to assign to it any rights of recovery you may have against others.
ANSWER NO. 15: Plaintiff objects to this interrogatory as it seeks to violate the Collateral Source Rule, the information sought is irrelevant, and the discovery of which is not likely to lead to information that would be admissible at trial. Furthermore, the information’s probative value would be outweighed by its prejudicial effect; however, without waiving said objections, Plaintiff received benefits from Gallagher Basset through the Workers’ Compensation Commission, and Blue Cross Blue Shield.
INTERROGATORY NO. 16: With respect to each of the past five (5) years, state your yearly gross income and yearly net income as reported on your federal income tax returns and state the name and address of the person, firm or corporation having custody of any papers pertaining to your income. If you did not file any federal income tax returns during this period, explain why.
ANSWER NO. 16: Plaintiff’s gross income was $69,587.00 in 2022; $39,949.00 in 2021; $46,183.00 in 2020; $16,261.00 in 2019; $47,015.00 in 2018; and $34,600.00 in 2017.
INTERROGATORY NO. 17: With respect to each of the past five (5) years, and at present, state the names and addresses of each of your employers, the dates of commencement and the termination of each employment, a detailed description of the work performed at each employment and set forth weekly wages or earnings from each employment.
ANSWER NO. 17: Plaintiff was employed by Mike’s Family Markets from 3/17/2019 to 9/20/2022 as a deli clerk and earned $15.25 an hour. The plaintiff resigned from Mike’s Family Markets to pursue a better opportunity with McDonald’s on a management track.
INTERROGATORY NO. 18: If you have lost any time from your employment, business or occupation since the occurrence referred to in the complaint, state the cause of such loss of time, the date(s) of such loss of time and the amount of wages or income lost.
ANSWER NO. 18: See above.
INTERROGATORY NO. 19: State the names and addresses of all persons known to you or to your attorneys who have given signed or recorded statements relative to all or any part of the occurrence and state the date the signed or recorded statement was given, to whom it was given and the present custodian of each such signed or recorded statement. Attach hereto a copy of all signed statements made by the party propounding these Interrogatories.
ANSWER NO. 19: Plaintiff objects to this interrogatory as it seeks to invade the attorney-client privilege and/or attorney-work product doctrine. However, without waiving said objection, Plaintiff is not aware of any such statements other than the incident report completed by David Holtman, Sr. Plaintiff reserves the right to supplement this Answer as discovery continues and additional information is made available.
INTERROGATORY NO. 20: If you know of the existence of any pictures, diagrams or objects (real evidence) relative to the occurrence or its consequences, state the nature, subject matter, date produced or obtained and the name and address of the present custodian of each.
ANSWER NO. 20: Plaintiff is in possession of photographs of the scene of the accident, photographs of Plaintiff’s injuries, a single photograph of the set cart, and video footage taken by security cameras at the Hyland during the load out on September 4 and 5, 2017.
INTERROGATORY NO. 21: If you contend that any document, letter, report, writing or any written instrument of any type or description is relevant to any issue in this case, identify each such written instrument, including the date and identity of the person preparing or signing such written instrument.
ANSWER NO. 21: Plaintiff objects to this interrogatory as it seeks to invade the attorney-client privilege and/or attorney-work product doctrine. However, without waiving said objection, Plaintiff will rely on any documents exchanged during the course of discovery.
INTERROGATORY NO. 22: State whether you have ever been convicted of any crimes, other than for violations of the Motor Vehicle Laws, and if so, set forth the nature of such crimes, the dates of each conviction and the name and address of the Court wherein each conviction occurred.
ANSWER NO. 22: Plaintiff objects to this interrogatory as the information sought is irrelevant, and the discovery of which is not likely to lead to information that would be admissible at the trial of this matter. Furthermore, the information’s probative value would be outweighed by its prejudicial effect. However, without waiving said objections, Plaintiff has not been convicted of any such crime.
INTERROGATORY NO. 23: If you consumed any alcoholic beverage of any type, or any sedative, tranquilizer or other drug, medicine or pill during the 48 hours immediately preceding the incident referred to in the Complaint, state the nature, amount and type of item consumed, the amount of time over which each was consumed and the names and addresses of any and all persons who have any knowledge as to the consumption of these items.
ANSWER NO. 23: Plaintiff denies the use of any such substance during the forty-eight (48) hours preceding the occurrence.
INTERROGATORY NO. 24: State whether you have within your control, or have knowledge of any transcripts of testimony in any proceeding arising out of the occurrence. If so, state the date, the subject matter, the name and business a
ddress of the person recording said testimony, and the name and address of the person who has present possession of each such transcript of testimony.
ANSWER NO. 24: Plaintiff did testify at his Worker’s Compensation Hearing.
INTERROGATORY NO. 25: If you have ever claimed any benefits under any insurance policy or against any person, firm or corporation for personal injuries and/or bodily injury which you have not heretofore listed in your answers to these interrogatories, set forth the nature of the injury or condition for which such claim was made, the name and address of the person, firm or corporation to whom or against whom the claim was made, the nature and amount of any payment received therefore and the date it was received.
ANSWER NO. 25: Plaintiff objects to this interrogatory as the information sought is irrelevant, and the discovery of which is not likely to lead to information that would be admissible at trial. Furthermore, the probative value is outweighed by the prejudicial effect; however, without answers to previous interrogatories.
INTERROGATORY NO. 26: If you contend that the party propounding these Interrogatories at any time made an admission against interest with respect to any issue involved in this litigation, state the date and place and in whose presence the admission against interest was made and the nature thereof.
ANSWER NO. 26: Defendant did make an admission as to the mishandling of evidence in this case. Discovery is ongoing, and this Answer may be supplemented.
INTERROGATORY NO. 27: If any of the persons named in response to the preceding Interrogatories are known or related to you, or to each other, state the nature of such acquaintanceship or relationship.
ANSWER NO. 27: Plaintiff knows Defendants from instituting the instant action and being involved in the accident, and has doctor-patient relationships with his healthcare providers. The individuals identified in these Answer to Interrogatories are identified by the nature of their relationship to the Plaintiff.
INTERROGATORY NO. 28: State the identity, part number and description of all of the components and parts of the product which is the subject of this suit which you alleged to have been defective in materials, workmanship, manufacture, design, or otherwise, specifying in your answer the exact nature of each such defect or defective condition and the manner in which you contend such defect affected the operation or safety of the road case and state the names and addresses of all persons having personal knowledge thereof and identify all documents that evidence your answer.
ANSWER NO. 28: Plaintiff claims that the set cart in question was defectively designed, defectively manufactured, and did not contain adequate warnings. The plaintiff has not been provided with any documentation as to the set cart. Discovery is ongoing and this Answer will be supplemented.
INTERROGATORY NO. 29: If you contend that any product or any of its component parts were defective by reason of design, then identify those parts and state in what manner you contend that such design was inadequate, improper or defective and include in your answer all facts or opinions relied upon by you in determining the state of the art, or advancement in technology, as of the time the product was designed and/or manufactured and all facts or opinions upon which you rely in asserting that the design of the product, or any of its component parts, deviated from or failed to meet or comply with the state of the art at the time of its design and/or manufacture and identify all documents that evidence your answer.
ANSWER NO. 29: Plaintiff claims that the set cart in question was defectively designed, defectively manufactured, and did not contain adequate warnings. The plaintiff has not been provided with any documentation as to the set cart. Discovery is ongoing and this Answer will be supplemented.
INTERROGATORY NO. 30: Name any person, not heretofore mentioned, having personal knowledge of facts material to this case.
ANSWER NO. 30: None other than those identified in these answers to interrogatories.
Respectfully submitted,
Miller & Zois, LLC
___________________________
OATH
I do solemnly declare and affirm under the penalties of perjury that the foregoing Answers to Interrogatories are true and correct to the best of my knowledge, information, and belief.
___________________________________
RICHARD DAVIS
How to Answer Interrogatories: Sample Responses, Strategy, and Legal Guidance
. Whether you are responding to discovery in a personal injury lawsuit, product liability claim, or another civil case, understanding how to frame your interrogatory answers can make or break your litigation strategy. From expert disclosures to objections and wage loss claims, the examples below reflect practical experience with the discovery process. These are especially helpful if you are looking for a response to interrogatories sample that strikes a balance between thoroughness and legal precision. The more realistic truth? You want to say a lot in your answers that say as little as possible without backing yourself into a corner at trial when these answers can be read to a jury.
What are interrogatories in a civil case?
Interrogatories are written questions exchanged between parties during discovery. They are designed to uncover facts, identify witnesses, and define the legal issues in dispute. Courts often require both parties to submit sworn answers to interrogatories early in the litigation process. Reviewing a sample response to interrogatories can help you see how these answers should be framed in both tone and content.
What should I include in my answer to interrogatories?
A proper answer to interrogatories should be accurate, complete, and tied directly to the question asked. You should include facts, dates, names, and supporting documentation where applicable. The most effective interrogatory responses are those that preserve your case theories while complying with procedural rules. Reviewing a well-prepared sample response to discovery requests can guide your approach.
Can I object to interrogatory questions?
Yes. If a question is vague, irrelevant, privileged, or overly burdensome, you can object. In our sample responses to interrogatories involving Walt Disney above, we made few objections due to the reasonableness of the inquiries. You do not want to send out a bunch of nonsense objections. But if you encounter unreasonable questions in your case, look at our complete list of interrogatory objections.
Do I need to disclose expert witnesses in my discovery responses?
Yes, absolutely. In civil discovery, particularly in injury or defect litigation, you are often required to identify expert witnesses and summarize their expected testimony. Our sample interrogatory answers include detailed expert disclosures that outline medical, engineering, and safety-related opinions. If you need help formatting this section, look for a sample response to form interrogatories with expert designations.
How do I format interrogatory responses for filing?
Once your interrogatory responses are finalized, you may need to prepare a clean version for filing with the court or serving on the opposing party. Many jurisdictions accept a printed answer to interrogatories in PDF format. Just be sure your responses are numbered clearly, signed under oath, and reflect any objections or supplements. And remember—discovery is ongoing, so you will need to update your answers as your case develops. It is easy to get burned at trial if you ignore this obligation.
Where can I find more examples?
If you are looking for discovery responses sample documents beyond product liability—such as sample answers to divorce interrogatories or civil discovery medical records sample questions—our legal resources include a variety of templates. Each sample response to interrogatories is crafted to help you understand how to write answers that are both effective and admissible.