Overview of Interrogatories in Discovery (2025 Full Guide)

Interrogatories play a key role in legal cases; their main purpose is to help attorneys gather critical information from the opposing party. But drafting them effectively isn’t always straightforward.

Asking the right questions requires a full understanding of the case, careful wording, and a strategic approach. At the same time, legal professionals must balance cooperation with protecting privileged information—all while keeping costs and billable hours in check.

It’s a delicate process, and mistakes can lead to wasted time, incomplete responses, or unnecessary disputes.

That’s why we created this guide—to break down the essentials of crafting strong interrogatories that drive cases forward. You’ll learn how to gather and share key details while avoiding common pitfalls that complicate litigation.

With the right approach, you can improve case outcomes and serve your clients more effectively.

Understand the Purpose of Your Interrogatories

Before drafting your questions, take a step back and clarify what you’re trying to accomplish. The stronger your strategy, the more useful the responses will be.

Are you gathering facts, identifying legal arguments, or uncovering key documents? Knowing your goals upfront will help you craft more precise and effective interrogatories.

Interrogatories often serve multiple purposes, so it’s important to be strategic in how you frame them. Here are some common objectives:

• Gather factual details – Ask for specifics about the case, such as the parties involved, potential damages, and the events leading up to the dispute. If the party served is a public or private corporation, you may also want details about company policies, employees involved, or internal records.
• Obtain key documents – Request financial records, written witness statements, police reports, or any other paperwork that could be relevant. This can help clarify the timeline of events and provide supporting evidence.
• Clarify legal arguments – Identify the statutes, case law, or legal theories the other party intends to rely on. This insight can help you anticipate their strategy and prepare counterarguments.
• Identify witnesses – Find out who was present at key moments and whether they can provide testimony. Their statements could shape the direction of the case.

Before you serve interrogatories, make sure each question has a clear purpose. Well-crafted interrogatories improve your chances of getting meaningful responses while keeping the process efficient and focused.

Learn to Respond Effectively to Interrogatories

If you work in the legal field, responding to written questions in interrogatories is a routine part of the job. But getting it right isn’t always straightforward.

The standard advice is to provide “complete and truthful” answers, but that’s easier said than done—especially when balancing client interests, legal strategy, and compliance.

A better approach is to be accurate and strategic. The answering party should rely on existing documentation whenever possible. Instead of over-explaining or speculating, refer to such records that already establish key facts.

If necessary, you can even choose to produce business records instead of drafting detailed responses, as long as the requesting party can locate the information within them.

It’s also important to recognize when objections are valid. If a request is overly broad, irrelevant, or unduly burdensome, the responding party has the right to push back. Thoughtful objections can prevent unnecessary disclosures and keep the case on track.

Finally, don’t rely on manual processing alone. AI-powered tools can sift through submissions, extract relevant details, and draft responses quickly. Automation can reduce the time spent on interrogatories while ensuring consistency and accuracy.

Draft Interrogatories Strategically

Drafting interrogatories takes time, so a strategic approach is key. Asking the right questions can uncover valuable case details, while vague or overly broad ones may lead to objections or unhelpful responses.

Here’s how to make your interrogatories more effective:

• Be specific – Avoid general questions that invite objections or unclear answers. If you’re using form interrogatories, customize them to fit your case instead of relying solely on standard templates.
• Follow a logical sequence – Structure questions so they build on one another. This forces the opposing side to follow your reasoning and limits its ability to give evasive responses.
• Target missing details – Use interrogatories to gather facts that can’t be found in available documents or witness statements.
• Avoid requesting legal conclusions – The opposing side isn’t required to provide interpretations of the law. Stick to factual questions to prevent objections.
• Request separate answers – Make sure each interrogatory is answered separately rather than grouped together. This prevents vague, all-encompassing responses.
• Consider the opposing strategy – As the interrogating party, frame your questions to reveal how the other side views key events. Their responses can provide insights into their legal approach.
• Submit early – Courts have deadlines, and early submissions give you time to review responses and plan your next steps.

Well-drafted interrogatories can strengthen your case, gather sufficient details, and keep opposing parties accountable.

Deal With Objections and Motions Effectively

Interrogatories don’t always go smoothly. Even if you follow best practices, objections and motions are common—sometimes as delay tactics. Whether you’re handling a car accident case or a complex corporate dispute, knowing how to push back effectively can keep things moving.

Start by reviewing objections carefully. Are they valid, or is the opposing side just trying to stall? In federal courts, objections must be backed by law, not just broad claims of over-generality.

If their reasoning is weak, push back and demand answers. If necessary, file a motion to compel the opposing party to respond.

If an interrogator asks you to disclose privileged information—especially in cases involving a governmental agency—consider seeking a protective order. Courts may allow you to limit disclosure to protect sensitive details.

When you serve answers, make sure they address all relevant questions while avoiding unnecessary disclosures.

AI tools like Briefpoint can help by identifying baseless objections, drafting responses, and managing legal correspondence efficiently. Instead of getting stuck in endless back-and-forths, you can focus on strengthening your case.

Make Interrogatories Less of a Hassle With Briefpoint

Interrogatories are a necessary part of discovery, but they don’t have to drain your time. Drafting, reviewing, and formatting responses manually slows everything down, taking focus away from case strategy and client needs.

Briefpoint changes that. Instead of getting stuck in tedious, repetitive work, legal teams can use automation to handle discovery responses faster and with fewer errors. Documents are formatted instantly, objections are managed efficiently, and responses are drafted in a fraction of the time.

The less time spent on paperwork, the more time there is for what actually moves cases forward. See it in action—schedule a demo today and let Briefpoint take care of the heavy lifting.

Automated Drafting Translates to Better Profits

Discovery responses cost firms $23,240, per year, per attorney. $23,240 estimate assumes an associate attorney salary of $150,000 (including benefits – or $83 an hour), 20 cases per year/per associate, 4 discovery sets per case, 30 questions per set, 3.5 hours spent responding to each set, and 1800 hours of billable hours per year.

Under these assumptions, you save $20,477 using Briefpoint, per year, per attorney.

Test Briefpoint yourself by scheduling a demo here.