After you file a lawsuit, the parties will begin the discovery process, where the opposing sides are required to provide documents and information to each other. Often the first requests for information come in the form of “Interrogatories” and “Document Requests.”

Explanation of Interrogatories

Interrogatories are allowed by Massachusetts Rule of Civil Procedure 33. Interrogatories are a list of written questions that each side is allowed to ask, and which each side is required to answer. A party who receives interrogatories has 30 days to provide written answers to each question. The answers must be given under oath as if the person signing them was testifying in Court. Parties are allowed to send more than one set of these questions; however, the total number of questions, or interrogatories, cannot be more than 30.

Just like questions asked in Court, a lawyer can object to an interrogatory on the client’s behalf. For example, if an interrogatory requires a party to reveal communications with their attorney, the lawyer can object because attorney-client communications are privileged. There are many different types of objections, but generally speaking if the interrogatory seeks information that is relevant and not privileged, the party must do their best to answer the interrogatory with the information requested, making sure the answers, which again are under oath, are as accurate as possible.

Explanation of Document Requests

Document Requests are another tool for discovery of information during a personal injury lawsuit. Document Requests are allowed by Massachusetts Rule of Civil Procedure 34. Document Requests are essentially a list of categories of documents that one party wants from the other. For example, a document request can ask for medical records relating to a person’s injuries, or documents relating to an accident or event. The word “document” is broad and can be anything from paper documents to electronic communications to tangible things like a vehicle or product (which are usually produced at an agreed date, place and time for “inspection”). Generally speaking, a party has 30 days to respond to document requests. And like Interrogatories, if a document request asks a party to provide documents or information that is privileged—like attorney-client emails—a lawyer may object instead of producing the documents.

How do Motions Filed in Court Affect Discovery?

When a party withholds information requested in an interrogatory or document response because of an objection, or refuses to provide information or documents requested, a party can bring a motion and ask the Court to decide whether the responses or objections were proper, and what information must ultimately be produced.

Getting information from the other party to a personal injury lawsuit —and pursuing that information through interrogatories, document requests, and motions with the Court—is one of the most important tasks a trial lawyer has. The pursuit of facts and information is what drives good results for a client, whether at trial or settlement. Similarly, responding to Document Requests and Interrogatories can be time-consuming and complex, and is an important aspect of a client’s case. For more information on filing claims for injuries, visit our blog explaining what damages can be claimed in a personal injury case.

Attorneys at SUGARMAN have decades of experience helping their clients navigate these issues to achieve the best outcomes for our clients. To learn more, please contact one of our partners by calling (617) 542-1000 or email us at