Form Interrogatory Definitions and Instructions
The following are integrated, edited Definitions and Instructions from different form Interrogatories that have been researched recently (specific sources included Georgia Litigation Forms and Analysis, Volume 2 by Thomas N. Autin, copyright 2008 by Thomson Reuters/West, and Brown’s Georgia Pleading, Practice and Legal Forms Annotated, Third Edition, by Charles R. Adams III and Cnythia Trimboli Adams, Volume 2 on Title 9 of Civil Practice (Chapter 11), copyright 2008 by Thomson Reuters/West):
You must answer each interrogatory separately and fully in writing and under oath, unless it is objected to, in which event the reason for the objection must be stated in place of the answer.
If you object to an interrogatory or request, in whole or in part, but provide an answer without making any waiver of your objection, please so specify that your answer is without any waiver of the objection, and the objection so raised, as well as either (a) all responsive information and documents requested, with said response being so specified, or (b) withholding the information or documents, and specifying that information is being withheld. If you are withholding documents, please identify them, providing enough information to identify the withheld documents or items for this party and the Court to determine whether the documents or items should be withheld.
Where knowledge or information of a defendant is requested, this request includes knowledge available to or possessed by the agents, representatives, and attorney of said Defendant, unless privileged.
Where the name of a person is requested, indicate the full name, home address, business address, e-mail address, and all available telephone numbers of the person.
Each interrogatory and each subpart of each interrogatory must be given a separate response. Interrogatories or subparts thereof may not be combined even when the response given to the interrogatories and/or their subparts are identical, or substantially similar. The answer to any interrogatory or subpart thereof may not be supplied by reference to a response to any other interrogatory or subpart thereof, unless the interrogatory or subpart thereof so referred to supplies a complete and accurate response to the individual interrogatory or subpart thereof which is being responded to initially.
If you are unable to provide an accurate answer to an interrogatory, or are uncertain regarding a response to any item, please provide your best estimate of the information requested, specifying that the answer is merely an estimate, and that an accurate response cannot be given by you to the item.
As stated initially in this document, these interrogatories will be deemed to be continuing in nature in order to allow supplemental answers so that your responses to each item remain accurate and complete if you or counsel representing you should obtain any further or different information between the time the answers to these items are made and the time of any trial on the merits.
Any objections to the interrogatories asked of you must be signed by the attorney or the unrepresented party making them, with the status of the person making said objection as represented or as an attorney, or a pro se person, so specified.
Definitions and Guidelines
For purposes of these interrogatories, the following definitions and guiding principles should be used, and will be deemed to apply for purposes of interpreting both topics of inquiry and responses thereto:
The term “person”, unless otherwise specified”, includes the plural as well as the singular, and includes in its meaning any natural person, or artificial or legal entity, including corporations, partnerships, joint ventures, associations, governmental agencies, groups, organizations, and any and every other form of entity cognizable at law.
The term “document” means and includes all written and graphic matter of every kind and description, whether printed or produced by any process or by hand, whether final draft or reproduction, whether in the actual or constructive possession, custody or control of the respondent to a given interrogatory, including any and all written letters, correspondence, memoranda, notes, statements, transcripts, files, charters, articles of incorporation, securities, bonds, stocks, certificates of deposit, evidences of debt, contracts, agreements, licenses, memoranda or notes of telephone or personal conversations, work papers, tapes, charts, reports, books, ledgers, telegrams, sound recordings, books of account, customer account statements, financial statements, catalogs, checks, check stubs, and written statements of witnesses or other persons having knowledge pertaining to the pertinent facts requested or relating to the interrogatory or subpart thereof, whether or not these documents are claimed to be privileged against discovery on any ground.
“You” or “your” means the person or entity to which the request or subpoena is directed, as well as his, her, or its agents, representatives, attorneys, experts, insurers, executors, administrators, or anyone acting on behalf of the person or entity, including any and all persons acting in the above-described capacity on behalf or purportedly on behalf of the person or entity to which the request or subpoena is directed.
The term “identify” means, when used with reference to an individual person, organization, corporation or association, to state the full name, home and work addresses, e-mail address, home and business telephone numbers, present or last known position and business affiliation and position both in the past and at the time said interrogatory or subpart thereof is being responded to.
The term “identify” further means, when used with reference to a document, to state the date it was created, its author, the signatory, if different, the addressee, the recipient of all copies, the type of document (e.g. chart, memorandum, letter, or other written document) and its present or last known custodian.
“Describe” means that the person or entity to whom the interrogatory or subpart thereof is directed should state what is requested to be described, including all facts and opinions known and held regarding, relating to, or pertinent to what is requested to be described, and (i) the identity of each person or entity involved or having any knowledge of each fact or opinion that relates to what is so described, (ii) the identity of each document evidencing the answer or response given or relating, referring or pertaining to said subject-matter in any way, and (iii) all relevant or material dates and time periods, specifying the way in which said dates or time periods are pertinent to the subject-matter described.
The term “____” refers to __________________________________________________.
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