What Are Interrogatories in Florida? How They Work and How to Answer Them

Daniel Reinfeld

3 days ago

8 min read

Hollywood Car Accident Lawyer | Daniel B Reinfeld, PA

Written and reviewed by Daniel B. Reinfeld, Esq. | Last updated October 26, 2026

Interrogatories are written questions that one party in a lawsuit sends to another, and the other party must answer them in writing and under oath. In Florida, Rule of Civil Procedure 1.340 governs them. Each side may serve no more than 30, counting every subpart, unless the court allows more. Your answers become part of the case record and can be used against you.

What are interrogatories?

Interrogatories are a written discovery tool. After a lawsuit is filed, a party can send written questions to any other party, and the receiving party must answer each one separately and fully in writing under oath unless it objects. Rule 1.340(a)(7) says so directly.

They serve a simple purpose. They pin down facts early and cheaply: who the witnesses are, what treatment you received, what you earn, what happened in the accident. The answers shape every later step in the case, including depositions, because the lawyer taking your deposition will have your interrogatory answers in hand.

How are interrogatories different from a deposition?

Interrogatories are written questions answered in writing, and a deposition is live testimony answered out loud. In a deposition the lawyer can follow up on anything you say. In an interrogatory the lawyer gets exactly what you wrote, which is usually carefully edited by your own attorney.

Interrogatories can only be served on a party to the case. A deposition can reach non-parties through a subpoena, as my article on what a subpoena is in Florida explains. Interrogatories are also different from a request for production, which asks for documents under Rule 1.350, and a request for admissions, which asks a party to admit or deny specific facts under Rule 1.370. Most Florida injury cases use all four, along with the deposition.

Who can serve interrogatories in Florida?

Any party may serve written interrogatories on any other party without asking the court first. Under Rule 1.340(a)(2), interrogatories may be served on the plaintiff after the action begins, and on any other party with or after service of process and the initial pleading.

When a company or other entity is the one answering, it responds through an officer or agent, who must furnish the information available to the entity. A corporate defendant cannot answer "I don't know" for facts its employees and records contain.

How many interrogatories can be asked?

No more than 30, including all subparts. Rule 1.340(a)(3) says interrogatories "must not exceed 30, including all subparts," unless the court allows more on motion and notice for good cause. The limit counts subparts, which means a single question with several lettered parts uses up more than one.

Where the Florida Supreme Court has approved a standard form for the type of case, the initial interrogatories on the covered subjects must come from that form. A party may serve fewer than all of the form questions. Added questions are allowed without leave of court only if the total of form and additional interrogatories stays within 30. The committee note to the 2024 amendment adds that any use of standard interrogatories must be adjusted for proportional discovery.

How long do you have to answer interrogatories?

You have 30 days after service of the interrogatories. A defendant has 45 days after service of process and the initial pleading. Rule 1.340(a)(9) sets both periods, and the court may change either.

That deadline applies to objections as well as answers. Missing it carries consequences, covered below. If you cannot finish in time, your lawyer asks for an extension before the deadline, not after.

Do you answer interrogatories under oath?

Yes. Each interrogatory must be answered separately and fully in writing under oath, unless the party objects to it. In practice, you sign a verification page that swears the answers are true, and a notary completes a jurat, or you sign a written declaration under penalty of perjury where Florida law allows one. My article on what an affidavit is in Florida explains both routes.

The oath is not a formality. A knowingly false sworn answer can expose you to a perjury charge, and a wrong answer that is not corrected will be used to impeach you. Read every answer before you sign, including the ones your lawyer drafted.

Can you object to interrogatories?

Yes, but objections must be specific and timely. Under Rule 1.340(a)(8), the objecting party must state the grounds "with specificity, including the reasons," and an attorney must sign the objections. A ground that is not stated in a timely objection is waived unless the court excuses it for good cause.

Valid grounds include that a question is outside the scope of discovery under Rule 1.280, is unreasonably burdensome, seeks privileged information, or exceeds the 30-question limit. A boilerplate objection that applies the same words to every question does little, and judges give it little weight.

An interrogatory is not objectionable merely because it calls for an opinion, a contention, or information outside your personal knowledge. Under Rule 1.340(b)(2) and (b)(3), you still must give the information you have and identify its source.

Can you answer by pointing to documents?

Sometimes. Rule 1.340(c) lets a party answer by identifying the records, including electronically stored information, from which the answer can be found, but only when the burden of getting the answer from the records is substantially the same for both sides. The answer must identify the records in enough detail to find them, and the other side must be given a reasonable chance to examine and copy them.

This is a legitimate shortcut for something like "list all of your medical bills" when the bills are produced. It is not a way to dodge a question that requires an actual answer.

What do interrogatories ask in a Florida personal injury case?

Interrogatories in an injury case usually ask who you are and how to reach you, how the accident happened, who saw it, what injuries you claim, which doctors you saw, and what you were paid for work you missed. They also ask about earlier injuries, earlier claims and lawsuits, other insurance, and your social media activity.

The defense uses those answers to check your story against your medical records and to look for pre-existing conditions. The most dangerous questions are the ones about the past. A prior back problem or an earlier claim that you forget or leave out will surface later, and the omission looks worse than the history itself.

How should you answer interrogatories?

Answer truthfully, completely, and only what is asked. Draft the answers with your lawyer, who knows which words create problems. Check every date, doctor name, and dollar figure against your records before you sign, and say "I do not recall" when that is true rather than guessing.

Three rules matter most. First, be consistent. Your answers must match your medical records, your deposition, and your earlier statements to insurers. Second, do not volunteer. Answer the question asked and stop. Third, if you learn that an answer was wrong or incomplete, tell your lawyer immediately so it can be corrected, because correcting an answer yourself and early reads very differently from being caught.

A qualified answer is one that adds conditions or hedges. Rule 1.340(b)(4) says it generally cannot be used as direct evidence or for impeachment unless the court finds it otherwise admissible. That is not a license to hedge everything. Courts expect real answers.

Can your interrogatory answers be used against you at trial?

Yes, to the extent the rules of evidence allow. Rule 1.340(b)(1) provides that answers may be used "to the extent permitted by the rules of evidence." If one side introduces an answer, the other side can require introduction of related interrogatories and answers that fairness requires under Rule 1.340(b)(5). Your answers are not binding on a co-party, under Rule 1.340(d).

A sworn answer that differs from your trial testimony is classic cross-examination material, which is why accuracy matters more than speed.

What happens if you do not answer interrogatories?

The other side can ask the court to compel answers and impose sanctions. Under Rule 1.340(a)(10), a party may move under Rule 1.380(a) over objections or a failure to answer. If a party disregards a court order to answer, the court can order further sanctions under Rule 1.380, which can include an award of the other side's expenses and, in serious cases, limits on the claims or defenses, up to dismissal or default.

Late and incomplete answers also hurt in a quieter way. A judge who sees a plaintiff ignoring discovery treats the plaintiff's later requests with less patience.

Frequently Asked Questions

What are interrogatories in simple terms?

Interrogatories are written questions that one side in a lawsuit sends to the other. The receiving party must answer in writing, under oath, within the time the rules allow.

How many interrogatories can be served in Florida?

Thirty, including all subparts, under Rule 1.340(a)(3). A court can allow more for good cause on motion and notice.

How long do I have to answer interrogatories in Florida?

Thirty days after service. A defendant has 45 days after service of process and the initial pleading. The court may change either period.

Are interrogatory answers under oath?

Yes. Rule 1.340(a)(7) requires each answer to be given separately and fully in writing under oath, unless the party objects to the question.

Can I refuse to answer an interrogatory?

You can object, but the objection must state its grounds with specificity and be signed by the attorney. An objection not made on time can be waived. If you object to part of a question, answer the rest.

What is the difference between interrogatories and a deposition?

Interrogatories are written questions answered in writing, and a deposition is oral questioning under oath before a court reporter. Interrogatories go only to parties, while a deposition can also reach non-parties by subpoena.

Can my lawyer answer interrogatories for me?

Your lawyer drafts the answers and signs any objections, but the answers are yours. You review them, verify them under oath, and are responsible for their accuracy.

What happens if I give a wrong answer to an interrogatory?

The other side can use it to impeach you, and a knowingly false sworn answer can expose you to perjury. Tell your lawyer as soon as you learn an answer is wrong so it can be corrected.

Call Today. Discuss Your Discovery Directly With Dan

Discovery answers shape your case for years. When you call Daniel B. Reinfeld, PA, you speak directly with Dan, not a call center, and he handles your case personally. Dan has practiced law in Florida for more than 25 years and spent years defending insurance claims before representing injured people, so he knows what the other side is looking for in your answers. Consultations are free, and there is no fee unless we recover for you. Dan meets by phone, Zoom, at the hospital, or at your home, with evening and weekend appointments available.

Call (954) 923-6110 or email dan@reinfeldlaw.com.

Hollywood office: 2450 Hollywood Boulevard, Suite 706, Hollywood, FL 33020. Open Monday through Friday, 9:00 a.m. to 5:00 p.m., with 24/7 live telephone answering. Fort Lauderdale consultations by appointment at 110 SE 6th Street, Suite 1700, Fort Lauderdale, FL 33301.

Sources: Florida Rule of Civil Procedure 1.340, Interrogatories to Parties (The Florida Bar, effective April 1, 2026); Florida Rules of Civil Procedure 1.280, 1.350, 1.370, and 1.380.

This article provides general information about Florida civil procedure. It is not legal advice, and reading it does not create an attorney-client relationship. Every case is different, and you should speak with a lawyer about your situation.