Exam 7: Discovery and Electronic Discovery: Overview and Interrogatories

Assume that you are the paralegal whose firm is representing the Briar Patch Dolls, Inc. in Case IV, the breach of contract case. Draft interrogatories to Teeny Tiny Manufacturing. Now, answer your own interrogatories for practice and to evaluate the quality of your interrogatories. Also practice objections and how to respond when unsure of your information in your answers.

Interrogatories should be answered

The federal rule of civil procedure that defines the general scope and limits of discovery is Rule

With mandatory disclosure, interrogatories

Trial preparation materials must be identified to the opposing party.

A report of the parties' planning meeting

Disclosure is required in all federal courts.

Answers to interrogatories should

Information stored in computers is secure, so its discovery can be left until later in the case.

What are the basic reasons discovery requests are objectionable under Rule 26(b)(1)? Explain each objection.

A preservation letter is best drafted in general terms so it can be used repeatedly.

Abbreviations are never allowed in interrogatories.

The parties' planning meeting is held after the scheduling conference or order.

On what grounds may a party refuse to produce requested e-information, and what types of e- information are most likely to be covered by those grounds?

Determine the elements of proof for the type of discrimination case in Case V, Rakowski v. Montez Construction Co. Place that information in your systems folder.

How can your understanding of the elements of the case help you in drafting interrogatories?

The primary purpose of the preservation letter is to facilitate the return of privileged information.

When does a party have a duty to update discovery information? What are the applicable federal and state rules?

When interrogatory answers are returned that need clarification, what are the options?

Not all courts require that interrogatories be filed.