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Don’t Let Your Opponent Bury You Under a Mountain of Business Records in Lieu of Answering Interrogatories

By Isaac Thorp

You have served interrogatories about the defendant’s construction of a defective roadway. The defendant responds to several of them by stating, “[T]he information sought by this interrogatory may be ascertained by a review of the construction diaries and other records. These documents are available for review, inspection and copying.” You arrive at defense counsel’s office to inspect the documents, and you’re directed to a storage room that contains 200 unlabeled boxes. “Good luck!” says his secretary, as she closes the storage room door. Is this proper?

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