Interrogatories may, without leave of court, be served upon any party after answer involves an opinion or contention that relates to fact or the application of law

The Court finds that Interrogatories 1, 3–5, 9–18, 22, 24, and 25 were properly propounded contention interrogatories, as CMS seems to acknowledge. These interrogatories deal directly with whether CMS has achieved unitary status. On the other hand, CMS’s objection to the timing of such interrogatories was not

Without leave of court or written stipulation, interrogatories may not be served because an answer to the interrogatory involves an opinion or contention that May 17, 2018 Second, Respondents' contention interrogatories are plainly improper and fly in the face of a long line of decisions rejecting exactly the kind of 33), and identify all documents relating to, and all persons having knowledge of, such alleged facts. 13. State all facts supporting Weiss' contention that. "[d] Interrogatories may, without leave of court, be served upon any party after answer involves an opinion or contention that relates to fact or the application of law Some courts do not require responses to contention interrogatories until near or at the close of discovery. In that case, you may have to evaluate the possible Interrogatory No. 5.

Contention interrogatories

757-631-3160. K9tr | 626-358 Phone Numbers 757-631-6762. Contention Personeriasm prearrestment. 757-631-7930 Under the Federal Rules and parallel state rules, litigants may use what are called "contention interrogatories" to explore adversaries' factual support for their legal contentions. Courts normally regulate the timing of those, generally prohibiting litigants from using that tactic too early in the discovery process.

R. CIV. P. 197.1. If the interrogatories are served by mail or fax before 5 Suggestions that the Rule specifically fix the number of interrogatories which can be submitted without leave of court was considered and rejected in favor of a more flexible limitation.

Form 2 - General Personal Injury Negligence-Interrogatories to Defendant (If answering for another person or entity, answer with respect to that person or entity, If so, state the full name and address of each such person or entity, the legal basis for your contention,

See Note to Rule 1, supra. References in Text.

Without leave of court or written stipulation, interrogatories may not be served because an answer to the interrogatory involves an opinion or contention that

“Contention interrogatories are premature if a propounding party cannot present plausible grounds showing that early answers to contention questions will efficiently advance litigation, or if the [answering party] does not have adequate information to assert its position.” Contention interrogatories are special that is designed to obtain information as to whether the opposing party will make a certain contention, and the facts and other evidence on which that contention is based. An interrogatory may relate to whether another party is making a certain contention, or to the facts, witnesses, and writings on which a The Limits on Contention Interrogatories There are important limits to contention interrogatories: 1.A party can only discover whether its adversary is “making a certain contention, or to the facts, witnesses, and writings on which a contention is based.” (Code Civ. Proc. § 2030.010(b).) By definition, this does not permit a party to request a list of 2018-02-20 In addressing this argument on a motion to compel, the court noted that contention interrogatories "seek to clarify the basis for or scope of an adversary's legal claims." They are not objectionable "merely because [they] ask[] for an opinion or contention that relates to fact or the application of law to fact." Contention Discovery. Discovery has just opened in your case and your client receives interrogatories. Within those interrogatories are some asking “state the facts upon which you intend to rely at trial to demonstrate plaintiff’s medical injuries are not causally related to the accident.”. 2009-05-12 Contention Interrogatories: , the rule thatprovides parties may Finally serve contention not interrogatories, which are inquiries intended to enable parties to learn other parties’ positions with Contention interrogatories highlight the critical role of timing in the work product doctrine context.

[a question asking] an opposing party to state all facts on which it bases some specified contention . . .
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2 pages) contention interrogatories with an exhaustive recitation of evidence would be improper, inconsistent with the case law and unduly burdensome and prejudicial, for at least three reasons. First, Complaint Counsel objected to Respondents’ interrogatories as overly broad and You should draft interrogatories contention interrogatories and other interrogatories seeking at specific response narrowly. But a big part of interrogatories is throwing out a big net to capture all the information that is out there that you may not have even considered. It is a bad idea to write interrogatories fearing objections. However, insofar as the interrogatories seek to ascertain the specific basis or bases, if any, for a contention that the attachment was vulnerable to pretrial attack, the trial court cannot refuse to compel answers on the basis that the interrogatories call for "legal opinion[s]." Uniform Contract Interrogatories.

An interrogatory is not objectionable merely because it asks for an opinion or contention that relates to fact or the application of law to fact, but the court may order that the interrogatory need not be answered until designated discovery is complete, or until a pretrial conference or some other time. Answers to interrogatories may be used only against the responding party at trial or a hearing.9 B. Interrogatory Types There are two basic types of interrogatories: identification and contention interrogatories.10 Identification interrogatories call for factual 7TEX.
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form interrogatories and special inter rogatories. Unfortunately, all too often, the defense interrogatories are prepared by an inexperienced attorney, generating extra billing hours by propounding use less repetitive questions which are often sent without regard to your client’s pri vacy rights or the relevant issues in the case.

contentment. contents. conterminous interrogatory. interrupt. interrupted. interrupter. interruption.

The legitimate purpose of contention interrogatories is to narrow the issues for trial, not to force the opposing side to marshal all its evidence on paper.

Uniform Contract Interrogatories. INSTRUCTIONS FOR USE. A. All information is to be divulged which is in the possession of the individual or corporate party, his attorneys, investigators, agents, employees or other representatives of the named party. B. When an individual interrogatory calls for an answer which involves more than one part, each 2009-06-01 2014-05-29 Title: US First Set of Interrogatories to Plaintiff. Created Date: 6/20/2008 11:55:44 AM Interrogatories must be crafted to seek information that could be used as evidence admissible in court.

[a question asking] an opposing party to state all facts on which it bases some specified contention . . . “Contention interrogatories are premature if a propounding party cannot present plausible grounds showing that early answers to contention questions will efficiently advance litigation, or if the [answering party] does not have adequate information to assert its position.” The Limits on Contention Interrogatories There are important limits to contention interrogatories: 1.A party can only discover whether its adversary is “making a certain contention, or to the facts, witnesses, and writings on which a contention is based.” (Code Civ. Proc. § 2030.010(b).) By definition, this does not permit a party to request a list of Contention interrogatories are special that is designed to obtain information as to whether the opposing party will make a certain contention, and the facts and other evidence on which that contention is based. An interrogatory may relate to whether another party is making a certain contention, or to the facts, witnesses, and writings on which a 2018-02-20 · These included contention interrogatories (the “Contention Interrogatories”) seeking “all facts” supporting allegations in NPI’s Second Amended Answer and Counterclaims (“SACC”).