Interrogatories aka How to Ruin a Perfectly Good Weekend

This past weekend I finally tackled what I've been putting off for nearly a month...interrogatories. Interrogatories are a list of questions opposing counsel wants answered to help them determine in advance what facts will be presented in trial (they, in turn, must respond in kind). This obviously takes place before depositions (ours have been scheduled the week of June 11, 2007).

I was given 30 days to respond. Normally, it wouldn't be that big a deal. However, it is the way in which they want you to respond that's such a pain in the arse. For example when they say they want you to "identify" a document it means they want you to:

"a) specify the nature of the document (such as, for example, a letter, memoranda, etc); b) state the date, if any, appearing on the document, or if not, the date on which such document was prepared; c) describe in general the subject matter of the document; d) identify each person who wrote, signed, dictated, or otherwise participated in the preparation of the document; e) identify each person(s), if any, who is an addressee thereof; f) if the document was at any time transferred between any two or more persons, identify which person(s) who were a party to the transer, and when the transfer occurred, and g) if the document now exists, identify each person having custody of the document"

We have collected documentation over the past three years! That's a lot of documentation to have to "identify." I'll share with you the answers I supplied (I stumbled across a short-cut) once my attorney gives me the go-ahead.