In an Oklahoma personal injury lawsuit, you answer interrogatories — written questions from the opposing side — in writing and under oath, usually within 30 days of being served. Answer every question fully and honestly with your attorney’s help; an evasive or incomplete answer counts as no answer at all and can lead to a motion to compel or sanctions.
If your Oklahoma personal injury case heads to litigation, expect written discovery within the first few months. An interrogatory is a formal written question from the opposing side — one discovery tool among several, alongside depositions and document requests — and Oklahoma law requires you to answer each one in writing and under oath. Many lawyers just mail clients the questions with instructions to “answer as best you can.” Here is what each type of question requires, what Oklahoma law says about deadlines and objections, and what happens if an answer turns out wrong.
The Four Basic Types of Interrogatories in an Oklahoma Personal Injury Case
Interrogatories generally fall into four types — list, yes/no (and if yes), narrative, and lawyer questions — and how you respond depends on the kind you are facing.
1) List Questions
List questions ask for information in list form: past employers, addresses, medical treatment, or witnesses who know about the case. Answer as completely as you can — leaving out a witness or provider can limit what evidence you can use later. A date range (say, March 2010 to February 2011) works when you cannot recall an exact date; if you truly cannot remember, say so and give what you have.
2) Yes/No, and if Yes, Questions
These start as a simple yes or no, usually followed by more detail if you answer yes — for example, whether you wore corrective lenses, had a prior conviction, or used alcohol or drugs before the incident. If the true answer is no, say “no” and stop there.
3) Narrative Questions
Narrative questions ask you to describe something in your own words: the incident, another party’s negligence, or your injuries. Keep answers brief but complete, and do not speculate — the rest gets explored in more detail once you sit down for your actual deposition.
4) “Lawyer” Questions
A handful of questions are really your attorney’s to answer — which experts to call, what evidence supports the claim, or settlement negotiations. Leave these blank for your lawyer to complete.
What Oklahoma Law Requires When You Answer
Oklahoma’s interrogatory statute, 12 O.S. § 3233, caps a standard set at thirty questions absent agreement or a court order. Every answer must be in writing, under oath, and personally signed by you (your lawyer signs only the objections), generally due within thirty days — though the clock does not start until an answer to the petition is filed, so your real deadline can land later than thirty days out. Skipping a question, or answering evasively, is not a safe shortcut: under 12 O.S. § 3237, an evasive or incomplete answer counts by law as no answer at all. The other side can ask a judge to compel a real one, and a court can shift attorney fees to you or, in serious cases, strike your claims entirely — reason enough to answer completely and truthfully, not to panic.
What Happens After You Return Your Draft Answers to Your Lawyer?
Send your drafted answers back to your attorney promptly — they still need time to review and finalize everything before the deadline. Keep your own copy to compare against the final, signed version, and fix any discrepancy before you sign under oath. If you realize later that something was wrong or left out, tell your attorney right away so they can file a supplemental answer. As the sanctions above make clear, dishonest or evasive answers can hurt your credibility and your case.
Interrogatory FAQs
What are interrogatories?
Written questions from one party to another in a lawsuit, part of the discovery process. They must be answered truthfully, in writing, and under oath.
How long do I have to answer interrogatories?
Generally thirty days after service — though see the Oklahoma-law section above for the exact rule on when that clock actually starts.
Can I refuse to answer an interrogatory question?
Not without talking to your attorney first. Oklahoma allows broad discovery questioning, so discomfort alone is not a valid reason to skip a question — your lawyer can object in writing where one genuinely applies.
What happens if I make a mistake or need to change an answer?
Tell your attorney immediately so they can file a supplemental answer. Fixing it yourself, early, beats letting opposing counsel find the discrepancy first — accuracy is what gives your case credibility.
What should I do if I don’t understand a question?
Ask your attorney before answering, so your response stays accurate and complete.
How detailed should my answers be?
Thorough, but not padded. Answer what is actually asked, and leave out what is not relevant.
Can interrogatory answers be used in court?
Yes. Because they are given under oath, your answers can be used as evidence at trial, including to challenge your testimony if it changes later.
Talk to an Oklahoma Personal Injury Lawyer About Your Interrogatories
Clayton Hasbrook has practiced Oklahoma injury law since 2008, and the attorney who personally reviews clients’ draft interrogatory answers before they go back to opposing counsel can look over your own set of questions first.
Hasbrook & Hasbrook offers a free consultation if you have questions about interrogatories or any other part of an Oklahoma injury claim. Call 405-605-2426 or reach out about your interrogatories anytime.
