The short answer
What Illinois families should know.
Interrogatories are written questions served on a party in a court case. Illinois Supreme Court Rule 213 governs their use and responses, including important witness-disclosure requirements. They are answered under oath or through proper objections. A lawyer can help frame a response, but the person supplying facts must review them carefully and provide accurate information.
Collect the information before drafting answers
Questions may ask about employment, accounts, property, debts, witnesses, or other facts connected to the dispute. Begin by identifying the records that can answer each question. A statement that you do not remember may not resolve a question that can be answered from available records. Explain missing information to counsel and distinguish what is unknown from what has simply not yet been located.
Watch the scope and the deadline
Rule 213 generally limits interrogatories to 30, including subparts, unless an agreement, court order, or applicable provision allows otherwise. It generally requires a sworn answer or objection within 28 days after service. Counsel should assess the particular request, service date, and any scheduling order. An objection should identify an actual issue rather than serve as a substitute for providing plainly discoverable facts.
Witness information deserves special care
Rule 213(f) calls for different information about lay witnesses, independent experts, and controlled experts. A witness's name alone may not satisfy the applicable disclosure obligation. The expected subjects, opinions, bases, qualifications, or reports may need to be described. The permitted trial testimony can be affected by what was disclosed, so unexpected testimony is not always a usable last-minute solution.
Keep the answers current
A case develops over time. A new job, newly discovered account, additional witness, or revised opinion may require supplementation. Tell counsel about changes instead of assuming the original answers remain adequate. Before signing sworn responses, check names, dates, amounts, and any statements described as estimates. A clear, candid answer is more useful than language that sounds certain but does not match the underlying records.
Prepare
Useful next steps
- Gather records that answer each numbered question.
- Identify witnesses and the specific facts each can address.
- Read the final sworn answers before signing them.
Avoid
Common missteps
- Signing answers you have not checked.
- Waiting until trial to disclose a new opinion or witness.
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This article provides general information and is not legal advice. Laws, court rules, local procedures, and individual facts can change the analysis. Reading it or contacting the firm does not create an attorney-client relationship.