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)
Labels: Rule 33(d)-Rule 34-Interrogatory-Answers-documents
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