Responses to Defendants’ Interrogatories in a state-of-the-art air quality lawsuit

As the attorneys for many corporate defendants and time billing lawyers in general tend to do, the attorneys for Hoerner-Waldorf sought to obtain information about the plaintiffs’ case by means of interrogatories.

Before filing the complaint, Counsel for Plaintiff should be prepared to provide support for and answer interrogatories concerning every allegation of fact in the Complaint.

The responses to Interrogatories from the Defendants afford the Plaintiff an opportunity for further public information and education as the responses become public record after filing with the Court.

The availability of this kind of detailed information about the technical elements of the plaintiffs’ case eases the ethical problems of the attorney, and the practical problems of the principal scientific witnesses in their dealings with media representatives. Rather than engage in long off-the-record/on-the-record discussions with journalists, counsel and the scientists can refer to the filed interrogatories as the principal statement of their position and summary of their direct testimony.

The following example of the Plaintiffs’ responses to the Defendant’s interrogatories in the Hoerner-Waldorf state-of-the-art air quality litigation show how Defendant’s interrogatories furnished Plaintiffs an opportunity to expand the allegations of the complaint and detail their claims.