Request for interrogatories example. Good luck with your case! Sample dog bite complaint.

Interrogatories are open-ended written questions that solicit information about a case. Offers interrogatories for both plaintiff and defense and each set of interrogatories features a summary of the topics covered by the questions along with the numbers of the questions that relate to that topic. referred to. In civil procedure, an interrogatory is a list of written questions one party sends to another as part of the discovery process. Gov. numbers, and present occupation or business affiliation; (2) when used in reference to a person. net INTERROGATORIES GENERAL OBJECTIONS: Complainant hereby OBJECTS to the Agency’s Discovery on the grounds that said Discovery is overbroad, vague, overly burdensome, requests irrelevant, immaterial or inadmissible information or information protected by privilege, and/or contains multipart questions in violation of law, rule or regulation. A. each document relied upon or which forms a basis for the answer given or which corroborates. 010, and that said answers be signed, verified, and served within thirty (30) days after service. Interrogatories and requests for admission are additional tools that parties can use to discover information before trial. Object to anything that is not relevant to the “subject matter” (no longer the standard) or not likely to lead to admissible evidence (no longer the standard). STATE OF SOUTH CAROLINA ) ) IN THE Forms. These Interrogatories shall be deemed continuing, so as to require additional answers if further information is obtained between the time answers are served and the time of trial. person, means that person's full name, last known address, home and business telephone. In a limited civil case (cases less than $25,000, or $35,000 if filed after Jan. To the extent that defendant obtains information or documents responsive to these discovery requests after filing its answers but prior to the commencement of trial or hearing, You have 30 days after the form or special interrogatories were served to you (35 days if served by mail from within California) to serve your responses to the interrogatories. G. Dec 3, 2018 · In some states, parties can request copies of relevant documents via interrogatories; in other states, a separate discovery tool called a Request for Production of Documents is used for this. For example, “What is the agency’s formal explanation for terminating the complainant?” Requests for admissions are closed-ended written statements that typically call for a “yes/admit” or “no/deny” response. Find court forms, sample letters, worksheets, and checklists on MassLegalHelp by legal topic. California law places strict limits on the number of discovery requests a party can make. For example: Free Consultation (800) 553-8082 Miller & Zois helps injured victims and their families in personal injury, medical malpractice and wrongful death cases. Read the Rule: Md. Below is a sample set of plaintiff’s product liability interrogatories to the defendant. 2: [copy interrogatory no. 24. Exhibit C – Sample Post-Judgment Requests for Production. These are basically fill-in-the-blank questions that will hopefully give a clear picture of your personal life Below are plaintiffs’ sample request for admission in a dog bite case. Normally, you can serve discovery (such as these interrogatories or document requests) after this Conference, though the Court may set a different Interrogatories, Set No. 2 days ago · Texas Rules of Civil Procedure 197 governs interrogatories. Federal Rule of Civil Procedure 33 covers interrogatories, and FRCP 36 covers requests for admission. Check that all questions are well-phrased and will obtain the desired information. 1 day ago · Generally, the party receiving the discovery request has 30 days to respond. Admissibility of computerized private business records, 7 A. Here are 2 ways to do discovery: • Written Questions (“Written Interrogatories”) (The court rule about these is CR 33. P. For each response: a) Identify by description, date, sender, recipient, location and custodian. 17. 21. Below are sample interrogatories in a dog bite lawsuit. Note there are limits on the number of interrogatories that may be sent to another party in the lawsuit. Oct 9, 2018 · Interrogatories are written questions (or requests for specific information) that are sent from one party to another. 20530, within 30 days of service of these Interrogatories. If the interrogatory is only partly objectionable, respond to the remainder of the. L. 6. If your case is an unlimited civil case (more than $35,000) form interrogatories are not counted against the amount of discovery you may ask. Requests for Production (Rule 34, SCRCP) in South Carolina. As to the person or persons who participated in responding to these Interrogatories please supply: Jan 22, 2022 · You may be able to find a PDF sample or template of basic interrogatories on the court's website. Requirements and rules for interrogatories differ among jurisdictions. _____ C. When the case was filed, the Clerk issued a document called an Initial Scheduling Order, which set the date of the Case Management Conference. Family Law Requests for Admission; Requests for Admission also utilize a judicial council form, the DISC-020, but they require that you actually draft the facts or identify the truth of the nature of the items that you are seeking have unequivocally and conclusively admitted. 340 (b). Your response must include the names of the requesting party and responding party, and the set number of the request. Sample Answers to Interrogatories. For more information on requests for production of documents see URCP 34. Permissibility of Discovery Tool. Plaintiff’s First Interrogatories to Defendant . All documents you intend to enter into evidence at a dispositive hearing or trial in this case. Mar 30, 2019 · Many plaintiff’s attorneys will object to these based on privilege grounds or that the request is premature. R. A few additional points about the number of interrogatories. explain why not. All organizational charts which include all employees in the direct supervision of _____ and _____ for the previous five years. . Our last module will cover requests for document production and physical and mental examinations. List all of your current or anticipated monthly expenses. D. Give the name, address, phone number, and occupation of the person who has. mail they have 7 extra days to respond. Requests for Admissions . With respect to each document produced, identify the person producing the document and the paragraph or subparagraph number of the request. Unless otherwise stipulated or ordered by the court, a party may serve on any other party no records request under the California Public Records Act (Cal. Response to Requests for Admission. The receiving party then has to respond, truthfully and in writing, within a specified period of time (exactly how long can vary by state; in Mar 21, 2024 · Rule 33 - Interrogatories to Parties (a) Availability; Procedures for Use. ] interrogatory no. In eviction ( unlawful detainer) cases the time is much shorter. to Defendant Carlos Mario Jimenez Naranjo. , who, what, when, where, how and/or why) exist that might support it. Federal Rule Civil Procedure 33(a) limits the number of interrogatories to 25 including subparts. 2. I hereby certify that a copy of the foregoing Plaintiff’s Second Set of Interrogatories has been sent via U. I will If your case is a limited civil case ($35,000 or less) you can request up to a total of 35 combined request for admissions, form interrogatories , special interrogatories, and requests for production. Sometimes, rather than answering the interrogatory, you may wish to object to the request on legal grounds. , and . Code § 6250 et seq. (a) Any party may serve, by mail or delivery by hand, upon any other party written interrogatories relating to any matters which may be inquired into under Rule 21. For the purposes of these Interrogatories, the term “high-cost loan” refers to a mortgage loan for more than $20,000, the total points and fees for which exceeds 5% of the total loan amount. The term “plaintiff” or “plaintiffs” means the party identified as such in this pleading. Box 364225. While they may have a point about the request being somewhat premature, they cannot rely on that excuse forever. ) CIVIL ACTION NO. Some exceptions and variations apply, so make sure you review how much time you have to respond depending on the type of case, the rules, and the type of discovery method used. FIRST SET OF INTERROGATORIES. For federal litigation, and in state courts which similarly limit discovery, the following sample interrogatories must be reduced to 25 interrogatories. San Juan, PR 00918. For example, “the incident” or “the Interrogatories are a list of questions you must answer in writing, and your answers must be signed in front of a notary. For example, you may want to submit a public records request for any Department of Fair Employment and Housing (DFEH) records related to the claims or a FOIA request for military Sample Product Liability Interrogatories. This interrogatory seeks what current facts (i. , "babysitting, $140. Interrogatory No. Local Civil Rules. Use boilerplate wording from form files. In eviction cases you have 5 days to respond, or typically 10 days from the date of mailing if served by mail. C. 26. Apr 19, 2024 · Sample interrogatories for many, many different types of cases organized alphabetically by topic. (a) Pattern Interrogatories for Specific Areas of Practice: (Reserved) Comment: The King County Superior Court will adopt a process for approving Pattern Interrogatories for use in discrete practice areas. There are numerous and conflicting decisions on the question whether and to what extent interrogatories are limited to matters “of fact,” or may elicit opinions, contentions, and legal conclusions. Written Interrogatories. 300, et seq. Plaintiff [CLIENT’S NAME] hereby requests that Defendant [DEFENDANT’S NAME] answer fully the following set of Special Interrogatories, in writing and under oath, pursuant to California Code of Civil Procedure. Form C. S. The focus of this series is the various issues which cause objections during the discovery process, outlined below: Introduction. ) or the Freedom of Information Act (FOIA) (5 U. Subdivision (b). CCP § 2023. For example, the same federal rule limits litigants in federal court to 25 questions each. [#] served on Defendant on [Date]. Plaintiff, v. Unless otherwise indicated, these interrogatories are to be answered with respect to Make sure the interrogatories are relevant to the issues in the case. Some include: Requests for Disclosures . B. The questions should be relevant to the ANSWER: REQUEST FOR PRODUCTION OF DOCUMENTS. Jan 18, 2023 · There is a sample request at the end of this guide. 1, 2024) you may ask each party only 35 questions total, whether they are form interrogatories, special interrogatories, requests for admission, or requests for production of Ronald V. There are various types of discovery requests in Texas. (410)760-8922 (fax) Sample interrogatories from the defendant’s insurance company (with answers) Sample discovery (depositions, requests for admission, etc. This Note also addresses when to file interrogatories and Consider using Form Interrogatories - General (form DISC-001) with interrogatory 17. You do not need to repeat the text of the request, but your responses must be in the same order as the requests, and each response must be Jun 28, 2024 · 197. So long as that motion is heard within 30 days of filing, it too can stave off the usable form. These interrogatories continue in Defendant. Such additional answers shall be served from time to time, but not later than thirty (30) days after such additional information is received. Any party may serve upon any other party written interrogatories to be answered by the party served or, if the party served is an organization including a governmental organization, or a partnership, by any officer or agent, who shall furnish such information as is available to the party. § 552). (NRCP 33; JCRCP 33) You have 30 days to respond to Form Interrogatories. URCP 6(c). An interrogatory is permissible even if the information sought would be inadmissible at trial, as long as the information sought appears reasonably calculated to lead Jul 20, 2021 · Definitions. May 31, 2017 · Make it a lead-off “general objection. Free Consultation (800) 553-8082 Miller & Zois helps injured victims and their families in personal injury, medical Example Dog Bite Interrogatories. 2 to the best of your ability, as completely as Interrogatories. So if the plaintiff sues two defendants, the plaintiff is allowed to send each defendant 25 interrogatories. Plaintiff Michael Smith, by counsel, requests that Defendant, Anthony Roberts, answer the following Interrogatories under oath and in compliance with Rule 4:8 of the Rules of the Supreme Court of Virginia, subject to the instructions below. And even then, the dilatory party may file a motion to extend his time to answer. If the court doesn't have a website or doesn't have documents available there, ask the court clerk or talk to the librarian of the public law library, typically located in the courthouse. O. Interrogatories 1. 00 pursuant to . Feb 15, 2023 · In federal court, for example, the parties are limited to 25 interrogatories per opposing party. All questions must be answered unless the court otherwise orders or unless a claim of privilege or protective order is made in accordance with R. If you were served by mail, you typically have 35 days from the date of mailing to respond. Don't forget to recheck all inserted info for correctness before submitting it or sending it out. Common objections include: The request is impermissibly compound. 010 et seq. Interrogatories . Interrogatories are written questions that are answered in writing under oath. (Caption) State: (a) the full name and residence address of each defendant; (b Laura G. Depositions . 2 from the plaintiff's request, word-for-word. Complainant, through her counsel, Snider and Fischer LLC, requests that the Agency respond to the following interrogatories. g. A party may propound to another party thirty (30) interrogatories, including those from the official forms or custom drafted ones. III. 4th 9. Section 2030. In legal terms, interrogatories are formal written requests — in the form of questions — issued by a party in a lawsuit to another party. Because attorneys may help their clients answer interrogatories, interrogatory responses tend to be more finely referred to. By exchanging written questions and responses, both sides can gain a clearer understanding of the facts, identify potential Mar 25, 2017 · Methods of Discovery in a South Carolina Lawsuit. Jun 2, 2009 · Interrogatories may relate to any unprivileged matter relevant to the subject matter of the pending action and relating to a claim or defense of any party. Our also attorneys provide more information on dog bite lawsuits and discovery below that can help you with deposition questions, interrogatories, and requests for production of documents. Construction LLC serves the following interrogatories on Defendants Base 360, LLC and Nicholas Gilley to be answered separately and fully, in writing and under oath, within thirty (30) days. Free Consultation (800) 553-8082 Miller & Zois helps injured victims and their PRACTICE TIP: Take a look at what the relevant rules require each party to produce, without a specific discovery request. The applicable rule for interrogatories is Rule 33 of the Federal Rules of Civil Procedure: “(a) In General. Case No. Baltimore, Maryland 21201. Get interrogatories and other discovery to serve on defendant in slip and trip cases. For example, the defendant in a personal injury lawsuit about a car accident might send you interrogatories asking you to disclose things like: Where you live. LCR 33. This limitation may be avoided only by leave of court or written stipulation of the parties. INSTRUCTIONS AND DEFINITIONS . INTERROGATORIES 1. A Practice Note discussing how to draft and serve interrogatories in a civil case in Texas district or county court. And each defendant can send the plaintiff 25 interrogatories. Uniform Interrogatories to be Answered by Defendant in All Personal Injury Cases: Superior Court. Timely updates. Here are some general characteristics of interrogatories to keep in mind: Interrogatories are written questions; The receiving party McConnell Valdés LLC. [#], Interrogatories Nos. 1. The term “defendant or defendants” means any or all of the parties to this litigation who are delineated as defendants in these pleadings and Generally, a party has 28 days to respond to a request for production of documents, but if the requests were served by U. The responding party must serve a written response on the requesting party within 30 days after service of the interrogatories, except that a defendant in a suit governed by the Family Code served with a request before the defendant's answer is due need not respond until 50 days after Discovery requests samples in personal injury lawsuits. Judgment in favor of plaintiff in state court action for defendant's failure to obey request or order to answer interrogatories or other discovery questions, 30 A. 4:17-1(b)(3). Reduce the time you spend on completing documents Here is a simple sample form that you might use as a template. State the name and address of any accountant, tax preparer, bookkeeper and other person, firm or entity who has kept or prepared books, documents and records with regard to your income, property, business or financial affairs during the course of this marriage. Baltimore, MD 21202. Where you work. If you do not attach the copy, describe the document, including its date. ) More sample interrogatories. ) A person who receives interrogatories has 30 days to respond in writing. ] response to interrogatory no. The process and the pattern interrogatories will be available from the KCSC Gibbon (S. Mental or physical examinations Oct 6, 2022 · Figure out when you can first serve interrogatories. A. 00; clothing, $30. The plaintiff can send the interrogatories to the defendant, and vice versa. Your state’s rule may differ slightly, but this will be a good example. [SAMPLE INTERROGATORIES – GENERAL] INTERROGATORY NO. For a more complete list of court forms, see the Massachusetts court website. 2 Response to Interrogatories. (a) Time for response. Provide copies of any and all correspondence between Agency officials, Any refusal to cooperate with a discovery request should be thoroughly discussed with your attorney. 2: [answer interrogatory no. 3d 1089. Requests for production (informally referred to by some as “requests to produce”) under Rule 34 can be sent to the other side of the case. Rule 2-421 (Circuit Court) Dec 20, 2014 · DEFENDANT’S ANSWERS AND OBJECTIONS TO PLAINTIFFS’ FIRST INTERROGATORIES, Page 5 6. the document. 1, 2024) you may ask each party only 35 questions total, whether they are form interrogatories, special interrogatories, requests for admission, or requests for production. Republic objects to each request on the grounds that they impose an undue burden on Republic, having been served (following months of Plaintiffs’ inaction) so as to require Republic to during a period answerthat includes nearly a week of holidays. For additional helpful interrogatories to consider asking, California provides so-called “form” interrogatories specific to employment cases, and although the form itself can be used only in California state courts, it may provide helpful ideas for interrogatories in federal cases. ] State whether or not you had a valid driver’s license at the time of the accident, and if you did not, state when you first became aware you did not have a valid driver’s license, and the circumstances that caused you to Legal Malpractice in Maryland (an overview) If you are looking for assistance in handling your legal malpractice case, call 800-553-8082 or get a free online no obligation consultation. The most frequently used methods of obtaining discovery are explained in this list: 1. Outside the Scope of Discovery. SAMPLE CIVIL FORM 47 IN THE _____ COURT OF _____ COUNTY A. These are directed to the landlord but can be easily refitted to address the dog’s owner. Exhibit B – Sample Post-Judgment Interrogatories to a Corporation or LLC. Dec 28, 2020 · First, in federal litigation, Federal Rule of Civil Procedure 33 states that parties can only serve interrogatories on other parties, but not third-party witnesses. IN THE UNITED STATES DISTRICT COURT. Rule 23. 15. R. (b) A party may propound more than one set of interrogatories to an adverse party, but the total number of interrogatories As an example, we can look at the Federal court rules. If asked to IDENTIFY A DOCUMENT, attach a copy of the document, unless you. 1: Please identify all of the individuals who were involved in the preparation of these answers to interrogatories, including their full name, job title, employer, business address, and telephone number. You are required to respond to these interrogatories no later than thirty (30) calendar days Overview. Sample interrogatories for the plaintiff in a slip and fall lawsuit. LAINTIFF’S INTERROGATORIES AND REQUEST FOR PRODUCTION TO DEFENDANT (XYZ) TRUSTDEFINITION OF TE. Zois. Help in providing responses required for answering written discovery questions. request, word-for-word. The purpose of interrogatories is to learn a great deal of general information about a party in a lawsuit. At the bottom are sample interrogatories the plaintiff can expect in a product defect, manufacturing defect, or defective warning case from the defendant. The requests for documents intermingled with the interrogatories herein shall be treated as formal requests for the production of these documents under Rule 34 of the North Carolina Rules of Civil Procedure if voluntary submission of said documents is not obtained. Request for Production, Inspection, or Entry . For the purpose of these Interrogatories only, Plaintiff has used the definitions set forth below. Expand All. Carefully review the Complaint, alleged facts, causes of action, and affirmative defenses when preparing interrogatories. Answers to interrogatories as limiting answering party's proof at state trial, 86 A. (Standard General Def. interrogatory as set forth above. Rule 3-421 (District Court); Md. Requests for Admission interrogatory. Notice is furthergiven that Plaintiff will request that the Court award monetary sanctions against Defendant and Defense Counsel, and in favor of Plaintiff in the sum of $1,060. 4th 8. May 28, 2009 · An interrogatory may ask for an opinion or contention that relates to fact or the application of law to fact, or that asks for information not within the personal knowledge of the party. O. Responses (or lack of response) to “contention interrogatories” can provide the basis for a summary judgment. Interrogatories concerning marriage and children relate to the marriage between Jan 19, 2023 · Yes. Certificate of Service. There is a sample request at the end of this guide. : 74918) ^ost Office Box 2980 55 East Camperdown Way, Suite 300 (29601) Greenville, South Carolina 29602 (864) 239-4000 ATTORNEYS FOR DEFENDANT, ANYWARE, LLC D/B/A ANYWARE EXPRESS July , 2018 5 ELECTRONICALLY FILED - 2018 Nov 21 10:35 AM - GREENVILLE - COMMON PLEAS - CASE#2018CP2303185. Don’t say if anything is being withheld on the basis of the objection. ”. 22. This requires the other side to provide additional information about any Request they do not admit, including the facts supporting their denial, the identity of the persons with knowledge of those facts, and the Rule 33 (a) thus gives a party, in the case of original interrogatories, 75 days, and in the case of further answers, 60 days, to file answers before the guillotine can fall. When satisfied with the draft interrogatories, you can proceed to the next step. This Note explains how to draft the case caption, introduction, instructions, definitions, interrogatories, signature block and certificate of service. The duty of a party to supplement his answers to interrogatories is governed by a new provision in Rule 26(e). Sample answers to interrogatories in personal injury auto accidents. CCP § 2030. e. Produce any and all Deeds, Deeds of Trust, Closing Statements, Orders for Distribution, or other documents which identify each parcel of real property set forth in response to the foregoing interrogatory. Instructions 1. Opposing lawyers want to guarantee a mutual understanding for ambiguous terms that can become muddled in the litigation process. Some sample probate interrogatories such as this one lays out key definitions beforehand that will be included in the Interrogatory Questions section ahead. A Request for Production of Documents is a request to a party to hand over certain defined documents. J. Here are 2 ways to do discovery: Written Questions ("Written Interrogatories") (The court rule about these is CR 33. Vagueness, Lacks Specificity, or Ambiguity of COMPLAINANT’S INTERROGATORIES. If you do not respond, the C. Depending on the discovery level in the case, litigants may request as many as 25 interrogatories. W. These requests might include: Interrogatories, which are written questions about things that are relevant or important to the case. Mail, first-class, postage prepaid, on the 17th day of July, 2021__, to: State Farm. See full list on legaldictionary. Interrogatories, requests for production, depositions, request for admission, naming experts, etc. (410)779-4600. 1 South St, #2450. You must respond to each request individually. Depending on where the case is filed, a personal injury lawsuit might involved one or more different types of interrogatories, including: The location of all copies of each such document. State the name and address of each person who saw plaintiff's accident as alleged in the complaint. Right after you’ve executed all of the actions above, you'll have the capacity to complete, print, and sign the Alabama Interrogatories sample. List all of your current or anticipated monthly expenses that relate to only your child’s or children’s expenses, e. 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. 5. You are required to answer these interrogatories separately and fully in writing, under oath. 1 checked when you use Request for Admissions. Identify the person(s) who answered or participated in answering each of these interrogatories for Defendant. Civ. The recipient must answer in writing under oath and according to the case's schedule. If you are served with discovery, such as Interrogatories, you are required to respond by the stated deadline. (b) Identify, identity, or identification, (1) when used in reference to a natural. : 22-C-17-006028 OT. Sample Discovery in Personal Injury Cases Below are the links to examples of discovery you can use in preparing and defending negligence claims: Interrogatories Depositions Designation of This is an example of a defendant’s discovery requests to plaintiff. Wherever a request calls for the production of a document claimed to be privileged, identify the document and include what privilege is claimed and the basis for the assertion of such claim. , Room 400, Washington, D. 25. IN THE CIRCUIT COURT FOR BALTIMORE COUNTY, MARYLAND. Arizona actually has a standard set of sample interrogatories that can be used in family law courts. Interrogatories are part of “Discovery,” which is very common in court cases. Aug 30, 2021 · Philip Silberman August 30, 2021. Additionally, make sure to reduce subparts to facts, documents, and witnesses related to the primary contention or allegation. Any party may serve as a matter of right upon any other party written interrogatories not to exceed thirty in number to be answered by the party served or, if the party served is a public or private corporation or a partnership or association or governmental agency, by any officer or agent, who shall furnish such to interrogatories. 1: [answer interrogatory no. EXHIBIT “A” SAMPLE POST-JUDGMENT INTERROGATORIES TO AN INDIVIDUAL _____ INTERROGATORY #1. This offer is both for potential clients and potential referring lawyers. Interrogatories are written questions sent by one party to another to gather specific information about details of specific events, occurrences, and more. , Defendant ) INTERROGATORIES Plaintiff requests that defendant answer the following interrogatories: 1. Jun 28, 2024 · Rule 33 - Interrogatories to Parties (A) Availability-Procedures for use. For example, pursuant to FRCP 26(a)(1) (if required), a party's initial disclosures must include the identification of each individual likely to have discoverable information that the disclosing party may use to support its claims or defenses, along with the subjects of Jan 13, 2022 · For example, a plaintiff may send interrogatories to the defendant, and the defendant may send interrogatories to the plaintiff. Interrogatories. 00" but not rent, utilities, phone, etc. You must answer each interrogatory separately and fully in writing under oath, Choose a file format and download your document. This sample can serve as a starting point when drafting interrogatories. Fla. Lacks Specific Description within Request. Mario Jimenez Naranjo (“Defendant”) hereby responds to Plaintiffs’ First Set of Interrogatories. Good luck with your case! Sample dog bite complaint. Laura G. Aug 16, 2021 · While interrogatories might inquire about legal theories and factual bases for a claim or denial of a claim, this part of the discovery process does not require evidence to substantiate or refute a claim. (1) Number. Bar No. and nature. These interrogatories and document production requests are of a continuing nature. , Plaintiff ) v. (410)760-8922 (Fax) Attorneys for the Plaintiff. 9-11-26(b)(1). 4. Miller, Jr. Parties may not be able to ask unlimited questions by interrogatory. Interrogatories are written questions sent by one party to the other party for the latter to answer in writing under oath. Maryland Personal Injury Lawyers. Once the draft interrogatories are ready, review them for accuracy and completeness. Pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure, defendant Carlos. 1 to the best of your ability, as completely as possible. Plaintiff requests that Defendant serve its answers, in writing and under oath, to the undersigned counsel for Plaintiff at 325 Seventh Street, N. Number of Interrogatories. th qn bp ct li kv ia tc zd dk