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Legal Memorandum: Answers to Interrogatories

Issue: What information must be included in answers to interrogatories?

Area of Law: Litigation & Procedure
Keywords: Answers to interrogatories; Information
Jurisdiction: Federal
Cited Cases: None
Cited Statutes: None
Date: 12/01/2008

A core concept of our rules of discovery is that answers to discovery must include all information within the party’s control, or known by the party’s agent.  Stated otherwise, a person upon whom interrogatories are propounded is bound to furnish relevant information from whatever sources are available to him, cannot claim ignorance in response to an interrogatory, or limit his answer to matters within his own knowledge, where the information sought is available from sources under his control.  See, e.g., Trane v. Klutznick, 87 F.R.D. 473, 476 (W.D. Wis. 1980) (concluding that “an official answering the interrogatories for a corporation ha[s] an affirmative duty to search out all information under the control of the corporation and [may] not evade answering the interrogatories based on his own limited knowledge”).

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