The way in which initial interrogatories are answered depends on the type of question asked; the four types of interrogatories are list, yes/no, narrative and lawyer questions -asked by the opposing counsel in cases that make it to litigation. Clients answer the questions in writing and under oath to give the opposing attorney basic information about the case.
List questions should be answered as thoroughly as possible; leaving information out when answering such questions can prevent witnesses or evidence from being used later in the case. Items knowingly omitted due to the inability to remember details should be noted in the answer. Persons answering list questions are advised to be specific with names and addresses but vague about their knowledge of the case's subject matter. Available records and notes should be referenced to completely answer these questions.
If the answer is "no" to a yes/no question, no further explanation is needed. When the answer is "yes," the rest of the question must be answered thoroughly.
Narrative questions should be answered as vaguely as possible while still providing a complete answer. Irrelevant details should be omitted, as these are covered at the deposition.
Lawyer questions should be left blank; the attorney involved in the case is responsible for these answers. These inquiries usually involve other evidence, experts or witnesses to appear at trial.