Discovery and Interrogatories: Answering the Other Side’s Questions
Once a lawsuit is filed, one of the first substantial tasks you’ll face is answering interrogatories — written questions from the other side that you must respond to in writing, under oath. For many people this is their first real taste of litigation, and it can feel daunting. It doesn’t have to be. Most of what’s asked is straightforward background, and the guiding principle is simple: answer truthfully and completely. Here’s what to expect and how to approach it.
Disclaimer: This post is intended for general informational purposes only and does not constitute legal advice. For guidance specific to your situation, please consult with a qualified personal injury attorney.
What Interrogatories Are
Interrogatories are written questions the defendant sends to you as the plaintiff, which you answer in writing and sign under oath. In King County, there’s a set of pattern interrogatories for car-accident cases — questions that a panel of plaintiff lawyers, defense lawyers, and judges reviewed and the court adopted as a standard, presumptively appropriate set. Parties don’t have to use them, but they often do, and defense lawyers in other counties frequently borrow them because they’re already vetted. You generally have a limited time to respond — commonly 30 days — which is one reason your attorney may send them to you early.
Much of It Is Background
A large share of these questions is simply biographical, and you’re often best positioned to answer them yourself as a first pass. Expect questions about:
- Your full name and any other names you’ve used, address history, date and place of birth
- Your education and employment history
- Marriages and children
- Driver’s license details and, sometimes, vision correction
- Medications or substances in the period before the collision
- Prior conditions, prior claims, and prior lawsuits
One recurring theme: many of these “one” questions actually contain several sub-parts. A single interrogatory might ask for a name, an address, dates, and more. The very first question, for instance, can bundle together your full name, prior names, current address, date of birth, place of birth, Social Security number, and every address you’ve lived at over a span of years — really seven or more answers wearing the disguise of a single question. The reliable approach is to break each question into its parts and answer them one by one, rather than giving a single general response that leaves gaps.
Employment and education questions work the same way, and they often reach back a set number of years measured from the date of the collision rather than from today. That can put the window several years further back than people expect, so it’s worth taking the time to reconstruct it carefully.
How to Answer Well
A few practical principles make this process go smoothly and protect your credibility:
- Answer truthfully and completely. The goal is accuracy, not advocacy.
- Answer what’s asked — no more, no less. You don’t need to volunteer a speech, but you shouldn’t shade or omit either.
- Don’t guess. If you genuinely don’t know or don’t remember, it’s perfectly acceptable to say so. Interrogatories ask for information available to you.
- Disclose the small, harmless things. If you had a single glass of wine the night before, or took an over-the-counter pain reliever, say so. These details rarely matter on their own — but leaving one out and having it surface later can make it look like you were hiding something.
- Identify everyone with knowledge, not just the people you like. When asked who knows about your injuries or losses, the question is about knowledge, not friendship or willingness to participate. Leaving out a coworker or family member you’d rather not involve can create problems later.
The Questions About Your Health and History
Certain interrogatories deserve special care because they’re the ones that most often trip people up. Questions about pre-existing conditions and prior injuries are typically broad and carry no time limit — they can reach back decades. If you claimed you were “sore all over” after the collision, you may be answering for every part of your body that has ever bothered you. Do your best to think back honestly; where you truly can’t recall specifics, say so rather than flatly denying. The danger isn’t having a prior injury — it’s giving an answer your other medical records will later contradict.
For the questions that get into the heart of your case — describing the incident, your injuries, your damages, and any wage loss — your attorney will typically work through these with you rather than leaving you to answer alone. Your attorney helps make sure the answers are accurate, complete, responsive, and based on a reasonable review of the information and records available — while also capturing things the records may have missed, such as scars, ongoing symptoms after treatment ended, or a doctor’s verbal advice about future care.
Final Thoughts
Interrogatories are less about strategy than about care and honesty. Handle the background questions thoroughly, don’t guess where you’re unsure, disclose the small stuff, and let your attorney help with the case-specific answers. Done right, they build a consistent, credible foundation for your case. Done carelessly, they can create contradictions that follow you all the way to trial.
If you’ve received a set of interrogatories and feel unsure how to approach them, reach out to our team. We help injured people throughout Washington answer these questions accurately and confidently — and we’re glad to walk through them with you.
