§ 140A.058.Interrogatories

The written-questions counterpart, and it is the shortest of the three.

Each interrogatory must be answered separately and fully in writing, unless it is objected to — in which case the basis for the objection shall be set forth in lieu of an answer.

"Separately and fully" forecloses the familiar evasions: answering several questions with one paragraph, or answering the question that was not asked.

Objection is available here, and that distinguishes interrogatories from testimony. A witness under oral examination may object only on constitutional or other privilege grounds and must otherwise answer; here any stated basis may be raised in place of an answer.

The reason is practical. A written answer can be withheld and litigated later without stopping anything; an examination in progress cannot.

The recipient must indicate in writing which answers contain trade secrets or confidential information — the same mandatory flagging the document section imposes.

Subsection (b) requires the same sworn certificate, and its scope is wider than the document one. Answers are certified by a person with knowledge that all of the requested information in the possession, custody, control, or knowledge of the person has been set forth fully and accurately.

"Or knowledge" is the addition. Documents are certified as to what a party holds; interrogatory answers are certified as to what a party knows, which reaches information that was never written down.