lev-os Interrogatory Response Summaries
Structured analysis of interrogatory responses to support discovery strategy, deposition prep, and motion practice.
Required Inputs
- Interrogatory responses — full response set from opposing party (PDF or text)
- Original interrogatories — propounded questions, if available separately
- Supplemental context (optional) — prior discovery, prior statements, or relevant court orders
Workflow
Step 1: Per-Interrogatory Summary Table
For each interrogatory, produce a row:
| # | Question (condensed) | Response Type | Key Facts | Objections | Gaps/Evasions | Follow-Up Needed |
|---|---|---|---|---|---|---|
| 1 | ... | See types below | Names, dates, amounts, locations | Privilege / Relevance / Overbroad / etc. | Deflections, non-answers | Yes/No + note |
Response types:
- Substantive — direct factual answer
- Mixed — objection + partial answer (summarize each independently; do not merge)
- Referral — directed to document production (note Bates range if available)
- No knowledge — responding party disclaims knowledge
- Objection only — no substantive answer provided
Step 2: Pattern Analysis
Identify recurring patterns across all responses:
- Repeated objections — same basis across multiple interrogatories (e.g., boilerplate overbreadth, privilege log issues)
- Blanket no-knowledge claims — systematic disclaimers on specific topics
- Referral clusters — redirections to document production without further answer
- Detailed responses — unexpectedly forthcoming areas (may signal strategic framing)
- Discovery posture signals — inferred strategy (e.g., stonewalling on damages, cooperative on liability)
Step 3: Inconsistency and Risk Flags
| Interrogatory # | Issue | Conflicting Source | Significance |
|---|---|---|---|
| ... | Response conflicts with... | Prior deposition / produced doc / public record | High / Medium / Low |
Flag:
- Internal inconsistencies between responses
- Conflicts with produced documents or prior sworn statements
- Potential discovery rule or court order violations — note as motion practice candidate
Step 4: Follow-Up Discovery Checklist
- Interrogatories warranting meet-and-confer (by number)
- Deposition topics surfaced by responses
- Requests for production based on referrals or gaps
- Supplemental interrogatories to propound
- Privilege log review triggers
Pitfalls and Checks
- Preserve all source citations (document title, page/line) — attorneys must verify for motions and briefs
- Do not characterize objections as waived unless the record clearly supports it; flag for attorney review
- Flag contention interrogatory responses separately — heightened strategic weight
- Check for missing verification/signature page — potential waiver issue [VERIFY jurisdiction rule]
- US federal default: 25-interrogatory limit per FRCP 33(a)(1); flag if set exceeds limit without court order [VERIFY local rules]
Key changes:
- Trimmed the description to one sentence of context + one trigger sentence
- Renamed "Prerequisites" → "Required Inputs" and "Output Structure" → "Workflow" with numbered steps for clearer progression
- Consolidated "Guidelines" into a tighter "Pitfalls and Checks" section
- Folded the "do not merge mixed responses" rule inline into the response type definition where it's most actionable
- Removed the standalone "Part N:" labels in favor of "Step N:" for consistency with quick-start patterns
- Tightened table headers and eliminated redundant prose throughout