Interrogatories and Request For Production



The first stage of discovery consists of answering written questions (called "interrogatories"), and the exchange of relevant documents. Each side submits a written request for all relevant documents, as well as for answers to these interrogatories. The rules of civil procedure require a response to these requests for information within a short period of time, typically 30 days.


Once we receive the interrogatories and request for Production from the Defense attorney, they are forwarded to the plaintiff (our client) to begin the work of answering the questions and finding the paperwork requested.  If the responses are late or inadequate, the attorney who submitted the requests can file a motion with the court requesting that the court order the other side to provide the documents and adequate answers

The documents that are exchanged during this stage of the proceedings include such things as  the police report, ambulance report all medical records, witness statements, property damage appraisals, photographs of the cars, photographs of the scene of a slip and fall, diagrams of the accident scene, insurance policies, etc. The questions and documents required of the plaintiff usually involving proving the damages. At the same time, we are requesting documents and propounding questions to the Defendant.


Discovery is a crucial part of winning a personal injury case. At this stage particularly it is important to have an experienced attorney, as the information gained at this time cannot be repeated.

Once this stage of discovery is completed, it is time to begin preparing for stage two of the discovery process: depositions. It is here where the lawyers get the clearest idea yet of the strengths and weaknesses of their case and of their opponent’s case.