Lesson #16 – For all Members


To obtain information from the adverse party, you can interrogate them by serving Interrogatories upon them, which are merely questions or requests for information that they must answer under oath.

You should use this discovery method prior to taking depositions, to save time and money, and so you can obtain information ahead of time and formulate your deposition questions based on the information you still need.

Here is a copy of an Interrogatories

When I sue my ex-wife’s attorney, I will use this discovery method to its fullest extent. I will pay particular attention to his answer to #3 to see if he casts blame on the judicial officials or anyone else for any part of his massive fraud upon the court in my ex-wife’s divorce, and to his answer to #6 because I will ask the jury to award my children and me his life’s work so he knows what it feels like to lose everything.

In Colorado, we are limited to 30 questions. However, to get the best results, we can structure our questions in such a way to obtain all the information relevant to that particular question. For example, I may rewrite interrogatory #6 as follows:

  1. List your assets, and for each asset:

(a) describe the asset in detail;
(b) state your percentage of ownership;
(c) state it’s location;
(d) estimate it’s fair market value.

Be careful, though, because the subparts of an interrogatory may be considered as separate questions; i.e. my #6 above would be considered four separate questions because it is not listed among Colorado’s approved ‘Pattern Interrogatories.’

I will be using the following approved pattern interrogatory (which will only count as one interrogatory):

Identify each denial of a material allegation and each affirmative defense in your pleadings and for each:

(a) state all facts upon which you base the denial or affirmative defense;
(b) state the names, addresses, and telephone numbers of all persons who have knowledge of those facts;
(c) identify all documents and other tangible things which support your denial or affirmative defense, and state the name, address, and telephone number of the person who has each document.

If the adverse party objects to any of your interrogatories, they must state the grounds for their objection (in Colorado, with ‘specificity’) and they must still answer the rest of the questions by the deadline. If an objection is made, you can move the court to compel an answer.

The answers to your interrogatories, and to your other discovery requests, can be used in your case and at trial to the extent permitted by your state’s Rules of Evidence, so make sure you familiarize yourself with that set of rules, as it will help you prepare to prove your case to the jury or judge at trial.

In the next lesson, you’ll learn about Subpoenas.