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LawTalk, Attorney and Counselor at Law
Category: Family Law
Satisfied Customers: 37855
Experience:  30 years legal experience. I remain current in Family Law through regular continuing education.
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HOW TO REVISE REQUEST FOR INTERROGATORIES - I'm pro se, ex husband has an attorney. They submitted a motion with a lot of lies and un-provable allegations. They are scheduling me for a deposition. I submitted to ex's attorney a Request for Admissions and Request for Interrogatories. They have since amended the motion and took out at least one lie and therefore, I'd like to change/remove or replace the questions that pertain to what they removed. I would rather ask a question based on the second amended motion since that has a new allegation. Can I send them a revised version and if so, do they get another 30 days?

Also, when I wrote the interrogatories, I wrote them like this, " 1. Describe in detail, the facts and provide any supporting information or documents which form the basis of your claim that ___________________, as stated section 4 (b) in your “Former Husband’s Verified Amended Motion to Enforce Shared Parental Responsibility Provision of the Parenting Plan” dated October 2, 2013. The problem is that now the motion he is operating under is the SECOND amended motion. Will he be able to disqualify the question because it refers to the original amended motion or would he still be required to answer because his SECOND amended motion has the same exact allegation?

Good afternoon,

I'm Doug, and I'm sorry to hear of the confusion. My goal is to provide you with excellent service today.

You will not need to revise the interrogatories that you already sent. Because you have new questions, you will simply need to send out a new set of interrogatories to the attorney and ask your new questions. And yes, they will get the 30 days to respond to those new interrogatories.

If the interrogatory referred to a motion, they will still have to respond to the question, despite the fact that they filed an amended motion.

Please keep in mind that, even though you have already paid your deposit money over to JustAnswer, until you rate me highly for my service, I will not be paid for having assisted you with your questions.

If you have additional questions, you may of course reply back to me and I will be happy to continue to assist you further until your questions have been answered to your satisfaction.

I wish you the best in your future.


LawTalk and 3 other Family Law Specialists are ready to help you
Customer: replied 3 years ago.

Hi and thank you. I am not quite clear on your answer. His attorney has done everything to make this process difficult so I want to make sure I cover my bases. I can only ask 30 questions and I don't want waste any questions that are now mute or want to give him another 30 days if I don't have to. Even though the amended motion and second amended motion have some of the same points, I am afraid his attorney is going to object to answering those questions that specifically refer to the "amended motion" numbers and bullet points not the "2nd amended motion".


Other than submitting a whole new replacement of interrogatories, how can I avoid him coming back and saying, "we can't answer that question because it refers to the amended motion NOT the 2nd amended motion", even though the allegations, bullet points are the same but may now have a different number and different name (2nd amended) of the motion.

1. I want to remove those questions that are mute. I don't want to waste my 30 questions on something they have withdrawn.

2. I want to clarify that any questions that were originally referring to amended motion, now refer to the 2nd amended motion, even if the bullet point is different.


Can I submit a Motion for Clarification or something I can file to clarify this?

Good afternoon,

You do not have the ability to remove questions, once asked. You may not amend questions once asked either. You may only file a new interrogatory set, or file an Amended interrogatory set correcting or re-wording your questions and serve it on the opponent before they respond to the set you initially served. Filing an amended Set of Interrogatories will result in the 30 days starting over again though, just as a new set of Interrogatories does.

You may reply back to me again if you have additional questions, and I will continue to assist you.

I wish you the best in your future,


LawTalk and 3 other Family Law Specialists are ready to help you
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