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Brandon M.
Brandon M., Family Law Attorney
Category: Family Law
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How do you answer and interrogatory question that is partially

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How do you answer and interrogatory question that is partially incorrect without admitting to the false information?
Hello there:

My name is XXXXX XXXXX I'm glad to help. Could you give a hypothetical example and an explanation for how a question might be partially incorrect? Does the question assume incorrect facts? For example, would the question be "why did you jump off the Golden Gate Bridge?" when you, in fact, only jumped off the Brooklyn Bridge?
Customer: replied 3 years ago.

Yes it assumes incorrect facts. Your example is spot on.

It's acceptable to object to an interrogatory, just like one would object to a question at a deposition or trial. It's also acceptable to object on multiple grounds. For a question like the hypothetical I gave, one might answer with something like "I object to this question on the grounds that it assumes facts not in evidence, it is confusing, it is misleading, it calls for a conclusion, it mis characterizes evidence, and it lacks foundation."

If it was strategically appropriate to do so, I might also add "Notwithstanding those objections I jumped off the Brooklyn Bridge in an attempt to reach and save a drowning cat." It might be strategically appropriate simply because you know that sooner or later, the other side will probably figure out a way to properly ask the information, so it can save some time and frustration by just giving them what they will ultimately want even though they didn't ask for it properly.

I will be straightforward that a significant number of those objections could be overruled if they stood alone, but (tactically), if you're going to raise an objection, you may as well throw in the proverbial kitchen sink.
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