What Are Interrogatories and How Do I Answer Them?

By: Mario Palermo of Palermo Law Group

As a personal injury attorney, I have helped countless clients navigate the complexities of a car accident lawsuit. One of the most crucial yet often confusing parts of the discovery process is responding to interrogatories. If you’ve filed a car accident claim or are defending yourself in a car accident case, you may have received a set of car accident interrogatories—written interrogatory questions that must be answered truthfully and under oath.

These questions help the opposing party, whether it’s an insurance company or another driver, gather critical details about the auto accident, including the time of the accident, medical treatment, and property damage. Your answers can significantly impact your case, which is why it’s important to handle them correctly.

In this blog, we’ll break down what car accident interrogatories are, why they matter, the most common sample interrogatories you may encounter, and how to answer them properly. Whether you’re the owner of the vehicle involved in a car crash or an injured party seeking compensation, this guide will prepare you to tackle this key stage of the legal process with confidence.

What Are Interrogatories in a Car Accident Case? 

Interrogatories are a critical tool in civil procedure, allowing both sides of a car accident lawsuit to gather relevant facts. They are part of the discovery process and consist of formal written interrogatory questions that must be answered in writing under oath.

Unlike depositions, which involve verbal testimony recorded by a court reporter, interrogatories give you time to craft thoughtful, accurate responses. However, they are legally binding, and any inaccuracies or inconsistencies could be used against you later in pleadings or at trial.

Why Are Interrogatories Important in a Car Accident Claim?

From the perspective of a personal injury lawyer, answering interrogatories properly can make or break your car accident claim. These written responses serve as a foundational element in your case, providing crucial information that attorneys, insurance companies, and courts rely on to determine liability, assess damages, and negotiate settlements. Here’s why they matter:

1. Establishing the Facts

The primary purpose of car accident interrogatories is to create a clear, documented record of what happened before, during, and after the accident. Your answers will clarify crucial details such as:

• The location of the accident, including road conditions, visibility, and whether any eyewitness were present.
• Whether you were engaged in any activities that could have contributed to the car crash, such as using your phone number to send a text message or consuming alcoholic beverages before driving.
• Whether the owner of the vehicle was driving or if someone else was operating the motor vehicle at the time.
• Whether you had preexisting medical conditions that are relevant to the injuries sustained in the crash. 

By providing accurate and consistent answers, you help solidify your version of events while preventing the opposing party from twisting or misinterpreting the facts in their favor. It is crucial to answer questions truthfully, even if you are concerned that the answers will hurt your case. Maintaining your credibility is essential.

2. Determining Liability

The insurance company and defense attorneys will carefully scrutinize your responses to determine fault. They may use your answers to:

• Identify inconsistencies between your interrogatory responses, depositions, police reports, and medical records.
• Compare your version of events with the opposing party’s statements and eyewitness testimonies.
• Use admissions regarding property damage, vehicle maintenance issues, or potential distractions (such as using your telephone number while driving) to shift blame.

Any inaccuracies, contradictions, or omissions in your responses can weaken your claim and may even be used against you in pleadings or at trial.

3. Evaluating Damages

Your answers to interrogatory questions will help assess the financial impact of the auto accident, including:

• The extent of your injuries, documented through medical history, medical treatment, and medical records.
• The cost of emergency care, surgeries, physical therapy, and ongoing rehabilitation.
• Proof of lost wages, including how your injuries have impacted your ability to work and earn income.
• Details about your insurance coverage, including your policy number, to determine how much compensation may be available.

A well-documented response can strengthen your case and ensure you receive fair compensation for both economic and non-economic damages.

4. Negotiating Settlements

When your responses align with the evidence—such as police reports, expert witnesses statements, and medical records—it can strengthen your negotiating position with the insurance company. By demonstrating consistency and credibility, you:

• Reduce the likelihood of the opposing party challenging your claim.
• Increase the chances of securing a favorable settlement without going to trial.
• Provide your car accident attorney with the leverage needed to advocate for a higher compensation amount.

If your responses contain contradictions or vague answers, the insurance company may attempt to undervalue or deny your claim, leading to prolonged legal battles.

Common Interrogatories in a Car Accident Case

If you are involved in a car accident case, expect to answer the following interrogatories:

A. Personal Information

• Full name, date of birth, social security number, telephone number, and phone number.
• Current and previous addresses.
• Employment details, including any lost wages due to the accident.

B. Accident Details

• Description of the car crash, including road and weather conditions.
• Who was the owner of the vehicle at the time?
• Were any eyewitnesses present?
• Were you using your phone number or sending a text message at the time?
• Did you consume any alcoholic beverages before the accident?

C. Injuries and Medical Treatment

• List any injuries sustained in the auto accident.
• Provide details about medical treatment, including doctors and hospitals visited.
• Submit medical records and confirm any pre-existing medical history.

D. Insurance and Legal Information

• Provide the name of your insurance company and policy number.
• Detail your insurance coverage, including any previous claims.
• If represented, provide details about your car accident attorney and law firm.
• Have you ever been involved in another car accident lawsuit?

E. Discovery and Documentation Requests

• Requests for production of documents, such as medical bills and police reports.
• Names of any expert witnesses supporting your claim.

How to Answer Car Accident Interrogatories Correctly

Interrogatories are a critical component of the discovery process in a car accident lawsuit. Since your responses are considered sworn testimony, they carry the same weight as statements made in court. A single mistake or inconsistency in your answers could negatively impact your car accident claim, giving the insurance company or opposing party ammunition to challenge your credibility.

Here are five essential steps to ensure your car accident interrogatories are answered correctly:

1. Be Honest and Accurate

Lying or omitting information in your interrogatory responses can be detrimental to your case. Even small inaccuracies—such as misremembering the time of the accident, the medical treatment you received, or your insurance coverage—can be used to discredit you. Some questions may require you to provide:

• Your full name, date of birth, and social security number for identification. You need only provide the last 4 digits of your social security number.
• Details about your medical history, including past injuries that could be relevant to your claim.
• Information about your motor vehicle, such as ownership details, accident history, or any mechanical issues that could have contributed to the car crash.

If you’re unsure about an answer, do not guess. Instead, consult with your car accident attorney to provide a response that is truthful while protecting your legal rights.

2. Keep Answers Clear and Concise

Interrogatories are not an opportunity to tell your side of the story in detail—your car accident lawyer will handle that later in the case. Instead, provide only the necessary information. For example:

• If a question asks for your telephone number, provide just the number—there’s no need to explain if it has changed recently or why you prefer one over another.
• If asked about the time of the collision, provide the exact time if known. If unsure, state that you do not recall rather than making an assumption.
• If asked whether you consumed alcoholic beverages before the accident, answer truthfully but concisely—elaborating unnecessarily can open the door for further scrutiny.

The insurance company or opposing party may try to use your words against you, so keep your answers brief and factual.

3. Consult Your Car Accident Attorney

Before answering car accident interrogatories, always seek guidance from your personal injury lawyer. They will:

• Help ensure your answers align with your personal knowledge and existing evidence, such as medical records, text messages, and insurance coverage details.
• Identify whether any questions are objectionable under civil procedure laws.
• Protect your attorney-client relationship, ensuring privileged communications with your law firm are not exposed.

Your lawyer will also prepare you for depositions, where the court reporter records your sworn oral testimony. Inconsistent responses between your written interrogatories and your deposition could weaken your case.

4. Use Legal Objections When Necessary

Not every question in an interrogatory set is fair or legally appropriate. Some may be irrelevant, too broad, or an invasion of privacy. Your attorney may raise objections to protect you from answering improper questions. Common objections include:

• Irrelevance – If the question does not relate to the subject matter of the case (e.g., questions about your financial status). Keep in mind that what’s allowable in discovery is far more broad than what then Judge will allow at trial. Discovery questions need only lead to discoverable information.  
• Attorney-Client Privilege – If the question seeks privileged communications between you and your lawyer, violating your attorney-client relationship.
• Speculation – If the question asks you to guess or assume facts rather than provide personal knowledge.
• Undue Burden – If the question requires excessive effort to answer, such as retrieving years of medical history unrelated to your injuries.

Your lawyer will ensure you respond only to relevant and legally appropriate inquiries.

5. Review Before Submission

Before finalizing your answers, take time to carefully review them with your attorney. Check for:

• Consistency – Your answers should align with police reports, medical records, and statements given to the insurance company.
• Accuracy – Ensure details such as your policy number, owner of the vehicle, and time of the accident are correct.
• Completeness – Verify that you have answered all required questions while avoiding unnecessary details.

By double-checking your responses, you can avoid discrepancies that could weaken your case during depositions or at trial.

Working with a Personal Injury Attorney for Your Car Accident Case

Navigating car accident interrogatories can be overwhelming, but you don’t have to do it alone. As a personal injury attorney, I know that strong, well-prepared responses can make all the difference in a car accident lawsuit.

At Palermo Law Group, our experienced personal injury lawyers will guide you through every step of the discovery process, ensuring that your answers protect your interests while strengthening your car accident claim.

If you need help with interrogatories or any other aspect of your auto accident case, contact our law firm for a free consultation by calling (630) 684-2332 or visit our website at https://www.palermolawgroup.com/.