Get Your Sample Interrogatories and Responses for Personal Injury Cases

When your client is served with interrogatories, the response is where the case is won or lost. A strong answer raises the right objections, ties every fact to the record, and reserves the plaintiff’s rights as discovery continues. This page shows what a strong interrogatory response looks like and gives you a downloadable sample: a full set of a defendant’s interrogatories with a plaintiff’s strategic answers. As of June 2026, it reflects the format EvenUp’s legal operators use.

What Are Interrogatories and Responses to Interrogatories (ROGs)?

Interrogatories are written questions one party sends to another during a lawsuit, answered under oath. Responses to interrogatories, often called ROGs, are the answering party’s sworn replies. In personal injury cases, a defendant serves interrogatories on the plaintiff to establish identity, how the incident occurred, the injuries claimed, the treatment received, and the damages sought.

A few terms are worth knowing. The propounding party is the side sending the interrogatories, the responding party is the side answering, and the verification is the sworn statement confirming the answers are truthful. For the plaintiff’s firm, the work is in the response: answering completely and consistently with the rest of the case file while preserving every available objection.

What the Sample Interrogatories and Responses Cover

The downloadable sample is a plaintiff’s answers to a defendant’s first set of interrogatories in an auto-accident case. It walks through eight interrogatories, each with the question as served and a model response, covering:

• Identity and personal information, including how to answer while objecting to overbroad requests for a Social Security or driver’s license number
• How the collision occurred, answered factually without conceding legal conclusions about fault
• Witnesses and law enforcement present at the scene
• Substance use before the collision
• Injuries claimed, documented against objective imaging and clinical findings, with permanency framed carefully
• Treating healthcare providers, itemized with specialties and dates
• Medical expenses, itemized by provider with a running total

How a Strong Interrogatory Response Is Structured

The sample shows the pattern that separates a strong ROGs response from a boilerplate one. It opens with a general statement preserving objections and the right to supplement, then answers each interrogatory in the same disciplined shape.

• Lead with the valid objection. Privacy, requests for legal conclusions, calls for premature expert opinion, and attorney work product are raised where they apply, not as blanket refusals.
• Answer subject to and without waiving. After the objection, the plaintiff still answers, which avoids a motion to compel while protecting the record.
• Tie every fact to evidence. Answers reference the crash report, vehicle data, medical records, and billing to be produced in response to requests for production.
• Reserve the right to supplement. Because treatment and discovery are ongoing, each substantive answer preserves the ability to amend as new information arrives.

That structure is what makes interrogatory answers do double duty: they satisfy the discovery obligation and build the plaintiff’s case at the same time.

Interrogatories Format and Structure

Every set follows a predictable structure: a caption identifying the case, a definitions section, instructions for responding, the numbered questions, and a signature block with the sworn verification. The specifics vary by court.

Common Objections to Interrogatories

Knowing the standard objections is what lets a plaintiff’s response protect the record while still answering. The sample raises several of these, each paired with a substantive answer rather than used as a blanket refusal.

Special vs. Form Interrogatories

Some jurisdictions, California in particular, offer form interrogatories: pre-approved sets courts have already vetted, which makes them harder to object to. Special interrogatories are custom-drafted to a case’s facts, which takes more effort but reaches details a form would miss. Many attorneys use both.

How to Use Interrogatory Responses in Trial Preparation

Verified answers become powerful tools as a case moves toward trial. Because the client’s responses are signed under oath, keeping them accurate and consistent with the rest of the file is what prevents the defense from using a contradiction for impeachment later. On the other side, the defendant’s answers to your interrogatories lock in their version of events and shape deposition strategy, and an incomplete or evasive defense answer becomes a natural area to press. When the defense’s responses are inadequate, a motion to compel may follow, and courts expect good-faith efforts to resolve disputes informally first, so documenting the attempt matters.

How EvenUp Drafts Interrogatory Responses

For a plaintiff’s firm, the time sink is the response: a defendant serves interrogatories, and the team has roughly 30 days to answer accurately and consistently across what can be dozens of questions. EvenUp’s ROGs templates are optimized to drive stronger, case-building responses, and AI Drafts generates them from your case files with line-level citations back to the record.

Answers stay consistent with the medical chronology, the demand, and the rest of the file, and the side-by-side view shows exactly which record each fact came from.

Frequently Asked Questions

What is a response to interrogatories?

A response to interrogatories, often called a ROGs response, is the answering party’s sworn reply to written discovery questions. In a personal injury case, the plaintiff answers each interrogatory under oath, raising any valid objections and tying the answers to the case record. The responses become part of the discovery record and can be used at trial.

How do you respond to interrogatories in a personal injury case?

Gather the supporting records first, then for each question raise any valid objection (privacy, legal conclusions, premature expert opinion, or work product), and answer subject to and without waiving those objections. Tie every fact to evidence that will be produced, keep answers consistent with the rest of the file, and reserve the right to supplement as treatment and discovery continue.