When sending interrogatories off to a junk debt buyer, you should try to list as many as possible. This forces them to work hard which not only costs them money but ticks them off too. They don’t expect you, or want you to come this far.

You must include all instructions and definitions pertaining to your interrogatories before listing them so that the plaintiff knows what you mean when you ask each question.

Interrogatories are by far the hardest part of discovery, because they must be done right; the questions must be good enough to get your case thrown out, and you must label instructions and definitions before sending them.

You cannot simply throw some questions together and send them off. You must give instructions and definitions beforehand. Otherwise, the plaintiff can easily not answer any of them and say they lack information or that they didn’t understand what you meant by the terms you used. In that case, they’ll get sent back to you with “lack of information” or “didn’t understand definition” and you’ll have to do them all over again.

During my lawsuit with a junk debt buyer I used 23 interrogatories, and before listing these 23 interrogatories I gave instructions and definitions. As a result of doing them correctly, they were forced to answer them.

This helped my lawsuit get dismissed. To see the interrogatories I used against LVNV click here.