While 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,” Rule 33 permits  

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Interrogatories may relate to any matters which can be inquired into under Rule 26(b), and the answers may be used to the extent permitted by the rules of evidence. An interrogatory otherwise proper is not necessarily objectionable merely because an answer to the interrogatory involves an opinion or contention that relates to fact or the application of law to fact, but the court may order that

Learn about why you should consult with a lawyer on any responses before you give them. Oct 31, 2018 What are interrogatories? Hi, I'm Dave Ward from the Ward Law Firm and we protect business owners facing divorce. As any divorce case goes  Feb 4, 2010 Responding to interrogatories properly is essential. Interrogatories can be used to help or hurt your case. While the laws concerning  Interrogatories. Most post judgment interrogatories will ask you everything about your assets.

Contention interrogatories

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In the joint stipulation, Bal Seal sought to compel responses to twenty interrogatories asking that NPI “state all facts” supporting allegations in its SACC. 2009-05-12 · Contention interrogatories seek to learn what those statements are intended to mean and the basis for making the assertion. The form of the interrogatory is often best written to quote the key phrase and identify its location in the Complaint or Answer. 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.”. 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 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.

514-967-0904.

Have you been given an interrogatory? Learn about why you should consult with a lawyer on any responses before you give them.

It did say that in some unusual cases a court could permit this approach. This section contains general damages contention interrogatories that are modified to apply in wrongful death cases.

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Civil Discovery Standard No. 8 of the American Bar Association (2004) establishes a guideline for the use of contention interrogatories. Interrogatories may relate to any matters which can be inquired into under Rule 26(b), and the answers may be used to the extent permitted by the rules of evidence.

. “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”). In the joint stipulation, Bal Seal sought to compel responses to twenty interrogatories asking that NPI “state all facts” supporting allegations in its SACC. 2009-05-12 · Contention interrogatories seek to learn what those statements are intended to mean and the basis for making the assertion. The form of the interrogatory is often best written to quote the key phrase and identify its location in the Complaint or Answer.
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Explanatory Note—2008. Civil Discovery Standard No. 8 of the American Bar Association (2004) establishes a guideline for the use of contention interrogatories. Interrogatories may relate to any matters which can be inquired into under Rule 26(b), and the answers may be used to the extent permitted by the rules of evidence. An interrogatory otherwise proper is not necessarily objectionable merely because an answer to the interrogatory involves an opinion or contention that relates to fact or the application of law to fact, but the court may order that "contention" interrogatories ask a party to identify all facts or evidence that supports a specific allegation in a complaint or a defense.

THINK Surgical, Inc., C.A. No. N16C-09-149-MMJ-CCLD, a special discovery master was tasked with resolving cross-motions to compel. “Missouri discovery rules allow so-called ‘contention interrogatories,’ which allow a party to discover the factual theory of the adversary’s case.
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(96 AD2d 493 [1st Dept 1983]) to support his contention that New York courts will reject interrogatories that are document requests in disguise, as such interrogatories impose an undue burden on one party to catalogue documents for another.

Plaintiffs were asked to. 3. Objection that Interrogatories Propounded by Plaintiff Constitute "an contention [; a]n interrogatory is not objectionable because an answer to it involves. INTERROGATORIES TO PARTIES Rule Number Subset: .02 merely because an answer to the interrogatory involves an opinion or contention that relates to  ates that an interrogatory is not objectionable because it asks for an opinion or contention that relates to fact or the application of law to fact.

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 

Rule 57.01 (c).” State ex rel. Dean v. Cunningham, 182 S.W.3d 561, 567 (Mo. 2006). 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. The potential for overreaching is particularly present when interrogatories seeking the detailed underpinnings of the opposing party’s allegations are served early in the case.

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