§ 140B.058.Interrogatories

The written-question rules, and the certificate at the end reaches further than the document one.

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

An objection is an answer for this purpose. Nothing may be left blank: every question receives either a response or a stated ground for declining, which is what allows a court to review the exchange later.

"Separately and fully" rules out the composite answer that addresses six questions at once and none of them squarely.

The person shall indicate in writing which answers contain trade secrets or confidential information, the same mandatory designation the document section imposes.

The certificate is where this differs from document production. Answers are certified by a person with knowledge to the effect 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 a wider net than "possession, custody, or control". A document search finds what exists on paper or on a system; this certificate covers what the person knows and never recorded.

For an organization that raises a real question about who signs. An entity knows what its people know, and a certificate about the knowledge of a company requires the signer to have canvassed those who hold it.

Interrogatories are also the least costly of the three forms to respond to, and the most exposed — an answer is a written statement made under oath, available to the issuing office and usable in the litigation that follows.