Fed.R. Civ. Pro. 33 (d): How Detailed Does a Response Need to Be Under Federal Rule of Civil Procedure 33(d) (Answering by Reference to Documents)

Courts have held that a party can only answer an Interrogatory by reference to documents if the reference is specific, detailed and identifies the documents that answer the question posed in the Interrogatory:

“[T]he producing party must adequately and precisely specify, for each interrogatory, the actual documents where the requested information will be found. Hillyard Enters. V. Warren Co. , 2003 U.S. Dist. LEXIS 27922,  (E.D.N.C.2003) ; Securities and Exchange Commission v. Elfindepan, 206 F.R.D. 574, 576 (M.D.N.C. 2002) ("Document dumps or vague references to documents do not suffice."). This requirement is meant "to make it clear that a responding party has the duty to specify, by category and location, the records from which answers to interrogatories can be derived." Fed. R. Civ. P. 33 advisory committee's note (1980 Amendment).”

Brown v. Blue Cross & Blue Shield of Ala., 2014 U.S. Dist. LEXIS 96105, *9 (W.D.N.C. July 15, 2014)(emphasis added)