I am involved in a civil suit. I am Defendant Pro Se. The Plaintiff is an attorney. He sent me a first set of interrogatories asking me to produce all photos and statements and estimates of repairs of damage. In all he sent me 14 different requests for production of documents. I left all of his requests blank because some were almost impossible to answer and I did not have the documents to send him. This case is only about $1800 damage this attorney did to our boat when if rented it and refused to pay. I now have a witness with photos and estimates of damage I wish to bring to trial. Because I did not answer his interrogatories what can I now do make sure the evidence I bring to court be be allowed? Trial is set for Feb 23, 2009.
charlotte, North Carolina
Good news! If you just recently located the witness and photographs, simply file supplemental answers to Interrogatories (or original, but late responses if you NEVER sent any response to the discovery) as well as a supplemental response to the Request for Production of Documents adding the new witness and providing copies of the photos.
That will do it. You'll be able to call the witness and use the photos at trial.
Best of luck to you.
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I am not clear I understand you. Do I file to the attorney or to the court. Do I just make a document and title it Supplement answers to Interrogatories and include copies of photos and witness and all the evidence I wish to bring and send it to the attorney? I don't understand what you mean about NEVER sent response to discovery. Try to make your answer more clear I am new at this
Hello,Did you ever send the attorney a document entitled Response to Interrogatories--or Response to Request for Production of Documents? Presuming that you did not, prepare two documents. They must have the court caption with the name of the court, the parties and action number (just like on the discovery he sent you). Title yours "Response to Interrogatories", or Documents......."The interrogatories he sent you were all numbered, as were the requests for production....Number your responses and answer the questions for the Interrogatories. For the production, for each of his numbers, state whether you have the documents requested and will comply with the request, or state that you don't have any such documents. Then enclose copies of the photos/documents and mail to the attorney.You do not send the documents or interrogatories to the court at this time, only to the attorney.
I am a practicing attorney with more than 27 years of experience in the legal field.
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