Plaintiff Attorney Legal Information CenterWritten interrogatories are an essential discovery tool for plaintiffs in all types of tort cases, especially personal injury claims. Whether you’re dealing with a car accident, medical malpractice, or product liability case, well-crafted interrogatories can serve as a foundation for building strong arguments and uncovering crucial facts early in litigation.
Unlike oral testimony in a deposition, where witnesses can hedge or revise their statements, written responses carry a greater sense of permanence. Once a defendant answers under oath, those responses are difficult to retract, making interrogatories highly effective in locking a defendant into specific positions on key issues.
On this page, we’ve provided sample interrogatory questions to defendant and sample interrogatory questions to plaintiff across a wide range of personal injury cases. These interrogatory examples are not generic boilerplate—they’re based on years of real-world litigation and have been tested in courtrooms across the country. Whether you’re looking for a sample of personal injury interrogatories or a broader interrogatories example to build from, these templates can help streamline your discovery process.
You will also find several examples of interrogatories designed explicitly for different tort categories, from premises liability to catastrophic injury. We’ve spent a lot of time refining these interrogatories examples so they reflect the nuances of actual litigation, not just textbook theory.
Feel free to adapt these sample interrogatories to your case. We’re offering them as a resource to our fellow plaintiffs’ attorneys with one goal in mind: to help you spend more time on high-value work and less time drafting from scratch.
That said, we encourage you to read and tailor these interrogatory examples carefully. While it may be tempting to cut and paste from a trusted source, failing to adapt interrogatories to the specific facts of your case can lead to embarrassment—or worse, judicial pushback. We’ve even heard of instances where lawyers submitted discovery with someone else’s case names and dates still included.
Used wisely, interrogatories are more than just a procedural formality—they are a strategic tool for developing a case. These sample interrogatories are here to support that effort and help you approach discovery with confidence and clarity.
Auto Accident Interrogatories
Full set of all 30 interrogatories for a standard auto accident case. For tactical reasons, consider serving them in parts.
The initial set is designed to funnel responses. Use before sets 2 and 3.
Follow-up questions to narrow the scope based on first responses.
The final set is used to lock in the defendant’s responses and position.
Interrogatories tailored to claims involving uninsured motorist coverage.
Sample interrogatories to a trucking company in a commercial crash case.
Questions aimed at the individual driver involved in the accident.
Medical Malpractice Interrogatories
Sample interrogatories and responses for a defendant doctor in a standard malpractice case.
Interrogatories to the OB/GYN in a birth injury case. Focused on initial fact-finding and care timelines.
Sample interrogatories from a wrongful death case involving malpractice and tort allegations against a nursing home.
Other Tort Interrogatories
Interrogatories to the defendant designer in a boiler and HVAC defect case at a school.
Initial interrogatories sent to the manufacturer of an allegedly defective medical implant device.
Interrogatories for a property owner in a lawsuit involving an apartment complex incident.
Sample interrogatories to the State of Maryland in a slip-and-fall case on public property.
Interrogatories submitted to a landowner defendant in a traditional premises liability action.
Initial interrogatories targeting the dog owner in a typical canine liability case.
Sample Interrogatories From Defendants
Below are samples of interrogatories we have received from common defendants in tort cases, such as insurance carriers. Defendants and their attorneys tend to use the same standard form interrogatories in all cases, so these examples should give you a good idea of what to expect.
Sample Interrogatory Questions and Answers
Your Questions About Drafting Interrogatories
Is There a Checklist I Can Follow to Answer Interrogatories?
This is a checklist you might want to consider:
- Check the deadline (usually 30 days, 25 in federal court).
- Send to your client quickly, then draft and fill gaps together.
- Read every word carefully—don’t skim.
- Spot objectionable questions and be specific with objections.
- Write in plain, jury-ready English.
- Review answers with your client before serving.
- Serve the final version on all parties.
Make sure your client owns the words—they sign under oath.
How Do You Draft Interrogatories in Personal Injury Cases?
What Is the Most Important Thing to Do After Serving Interrogatories?
The most important thing to do after serving interrogatories is to follow up—aggressively and methodically. Too many lawyers assume that meaningful answers will just show up in the initial response packet, but that’s rarely the case. Most responses come back late, full of boilerplate objections, evasive qualifications, and incomplete information. So once that response lands, your first move should be a meticulous review, line by line, noting anything vague, non-responsive, or clearly obstructive. Then, reach out with a targeted deficiency letter—not just for the record, but to signal that you will not let them skate. This puts the burden back on the other side to explain or supplement before you involve the court. And yes, that record matters later if you need to file a motion to compel—judges are far more receptive when you can show you tried to resolve things informally first.
What lawyers sometimes miss is that interrogatories are not about getting perfect answers on the first round—they’re about locking the other party into a position and forcing them to choose between answering now or getting nailed later for withholding. If they refuse to give up a name, a date, a document, they own that omission. If they say “we don’t know” or “not at this time,” make a note and come back to it at deposition or summary judgment.
In more significant cases, it is also wise to track which interrogatories tie into specific Rule 30(b)(6) topics or RFPs, because following up means cross-leveraging all discovery tools, not just writing a second letter. Bottom line: Interrogatories are just the start. The real work is in the follow-through—holding the other side’s feet to the fire, knowing what answers you should be getting, and being prepared to escalate when they inevitably stall.
Who Answers Interrogatories?
What kind of questions should you ask in interrogatories?
The answer is highly case-specific, of course. What is useful in a medical malpractice case is entirely different from what an attorney might ask in a breach of contract, employment discrimination, or product liability matter. The value of interrogatories lies in their ability to extract targeted information that aligns with the unique facts, legal theories, and burdens of proof in each particular case.
That said, generally speaking, effective interrogatories compel the opposing party to commit to specific facts early in the litigation, identify witnesses and documents they intend to rely on, and disclose the factual bases for their claims or defenses. The goal is not to solicit a broad narrative, but rather to pin down details that can be tested later in depositions or leveraged in dispositive motions.
For example, in a personal injury action, it would be appropriate to ask for a comprehensive list of prior medical conditions, the identity of treating physicians, and an itemized account of damages claimed. In a commercial contract dispute, interrogatories might focus on who negotiated the agreement, what pre-breach communications occurred, and who decided to withhold payment. In an employment case, counsel might seek information about comparators, decision-makers, and the stated reasons for adverse employment actions. The key is to use interrogatories to force the opposing party to reveal the structure of their case—the who, what, when, and how—so that depositions and follow-up discovery can focus more sharply on the why.
What type of information is most effectively obtained by interrogatories?
How many questions can you ask in interrogatories?
What if someone doesn’t answer interrogatories?
What are valid objections to interrogatories?
What happens if you lie on interrogatories?
Who signs the answers to interrogatories?
How do you respond to the plaintiff’s first set of interrogatories?
How do you write a good interrogatory?
What happens after interrogatories are answered?
What is the best use of interrogatories?
Can interrogatories be used at trial?
Interrogatories: How Plaintiffs Should Use Them
Interrogatories are written questions answered under oath. In most jurisdictions, parties may serve 30 written questions.
Because the number of requests is restricted without a court order or an agreement among the parties, interrogatories in a complex case should be carefully drafted to request only information that a lawyer cannot find using other discovery mechanisms.
Subparts are counted separately when determining the number of questions you can ask. So, asking an interrogatory with several questions does not help keep the number down. If an interrogatory has five related subparts, it will be counted as five interrogatories.
In 1994, Maryland Rule 2-421 was amended to allow a party to serve more than a single set of interrogatories. But the total number of requests cannot exceed thirty. Accordingly, we suggest serving more than one set. First, serve an initial set as well as later “clean-up” set so long as the total number of questions does not exceed 30. In the sample above, the first set listed assumes that all 30 interrogatories are asked at one time.
The next three sample sets are sent throughout the course of discovery. Defense counsel in a case recently refused to answer discovery because the defendant thought three sets of requests for admission and interrogatories were just too much. I do not think she has ever read Maryland Rule 2-421 or Maryland Rule 2-424.
Fortunately, we were sure that the judge who hears the motion to compel has read these rules. (Update: Yep, that is what happened!)
Another tactic that leads to quality information about the defendant’s case is using alternative interrogatories. These are used in conjunction with requests for admission. If a party denies a request for admission that goes to a critical component of Plaintiff’s personal injury case, an alternative interrogatory asks the defendant to set forth all facts and evidence upon which the defendant intends to rely upon at trial to support the defense lawyer’s denial. Attorneys hate taking positions before trial. (We do too.) So if you can pin down what the arguments will be, you will be in a much better position to structure your case effectively.
This rule does not direct how the questions are to be asked. It can be either in the form of a question (usually contention interrogatories), or it can direct the answering party to supply accurate information that is described.
Insurance defense counsel often refuses to answer discovery. They are simply seeking creative ways to avoid answering discovery. Why do they do it? Few plaintiffs’ attorneys hold their feet to the fire and make them answer in the face of silly objections.
Frivolous objections come in many shapes and sizes. The most classic objection is that the interrogatory asked is objectionable under Maryland law because it is “vague, burdensome, overly broad, and not reasonably calculated to lead to admissible evidence.” Many use this objection to the simplest of questions. As suggested above, you will often get this response even when you are using template questions employed by the court.
They also object because a particular word is not defined (no matter what the word is, right down to questioning what the definition of “is” is). Another favorite objection is that the plaintiff bears the burden, so no answer is required, an objection that is beyond silly.
No matter what the objection, the key is to object quickly and press the defendant with a motion to compel if necessary. The process adds layers of time, expense, and tedious effort because a motion must be drafted, and typically the judge will require the lawyers to attend a hearing on the motion. But the pursuit is worth getting proper and complete answers.
Think About How You Will Use Interrogatory Responses at Trial
The most valuable advice for drafting, responding to, and following up on interrogatories is something that many attorneys overlook: give thoughtful consideration to how the responses will be used at trial.
Too often, discovery is approached as a procedural obligation rather than a strategic opportunity. Attorneys receive an overwhelming amount of advice about discovery practices, yet the most impactful guidance is often the simplest: think carefully and deliberately about your endgame.
In the rush to meet deadlines and check boxes, it is easy to focus on making difficult or technical legal plays—what might be considered “diving, impossible catches.” But in doing so, many attorneys miss the straightforward, obvious points—the “fly balls” that could significantly advance the case with far less effort. Instead of treating interrogatories as a routine exercise, view them as a chance to shape the narrative of your case long before trial begins.
Consider what you ultimately need to prove to the jury. Identify the elements that must be established and the weaknesses in the opposing party’s position that should be exposed. Tailor your interrogatories to pursue those exact points. Think about the types of responses that will box in the defendant, forcing them to commit to a position from which they cannot easily retreat. Focus on securing admissions, clarifications, and explanations that can later be read directly to the jury as persuasive, binding statements.
Also, reflect on the specific nature of your case. Do not rely on generic discovery tools or form interrogatories without adapting them to the unique facts and legal issues at hand. Ask yourself: what would I want to stand up and read aloud at trial? What answer, if locked in under oath, would strengthen my opening statement or undermine the defense’s closing argument?
Then, draft your interrogatories with precision and purpose. Demand responses that are not only technically accurate but also candid and complete. When you begin discovery with the trial in mind, you move from a reactive posture to a proactive one—building your case strategically, one question at a time.
Focusing on this approach will yield far greater results than reading a thousand articles on how to craft discovery. Thoughtfully prepared interrogatories, aligned with your trial strategy, can become one of the most powerful tools in your litigation arsenal.
More Discovery Resources to Put Your Case Together
- Sample interrogatory objections
- Get more discovery examples
- Model form questions from California
- Take a look at a demand letter
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