Yes! You can use AI to fill out Form DISC-004, Form Interrogatories—Limited Civil Cases (Economic Litigation)

Parties often forget to fill out the entire caption at the top of the first page, omitting the Case Number, the correct court name, or the full names of the asking and answering parties. This happens due to oversight when rushing to complete the substance of the form. An incomplete or incorrect caption can lead to the document being rejected by the court clerk or causing confusion and delays in the legal process. To avoid this, double-check every field in the header before proceeding to the questions.

The answering party must sign a statement at the end of their answers declaring under penalty of perjury that the information is true and correct, as stated in Instruction 3(g). Forgetting this signature is a critical error that renders the entire set of responses invalid. The asking party can then file a motion to compel proper responses, causing delays and potential monetary sanctions. Always attach a separate, signed verification page to your final answers.

Instruction 3(d) requires the answering party to make a 'reasonable and good faith effort' to obtain information they don't personally know, unless it's equally available to the asking party. Many people mistakenly answer 'I don't know' without first checking with their employees, agents, or reviewing their own records. This is an improper response and can lead to legal challenges, as it fails to meet the discovery obligation. Before answering, you must actively seek out information within your control.

The form defines key terms like 'INCIDENT', 'YOU OR ANYONE ACTING ON YOUR BEHALF', and 'DOCUMENT' in Section 4. A common mistake is to answer questions without reading these definitions, leading to incomplete responses. For example, a question using 'YOU' requires information from your agents, attorneys, and insurance companies, not just yourself. This can result in evasive answers and motions to compel. Carefully review Section 4 before you begin answering any questions.

Interrogatories 102.4 and 102.5 specifically request residence and employment history for the 'last five years,' including dates. People frequently provide only their current information or an incomplete list, which constitutes an insufficient answer. This can damage credibility and lead to further, more detailed discovery requests from the opposing party. To avoid this, gather all relevant addresses, employer names, and date ranges for the full five-year period before you start filling out the form.

Interrogatory 104.1 asks for every insurance policy that may cover the damages. A frequent error is to list only the primary auto or home policy while omitting other potential coverage, such as an umbrella policy or a policy from an employer. This is a serious omission, as identifying insurance coverage is a primary goal of discovery. Failing to disclose all policies can lead to significant legal penalties if discovered later. Review all potential sources of coverage before answering.

Interrogatories 108.2 and 108.4 require you to 'show how you compute' your lost earnings. A common mistake is to simply state a total dollar amount without providing the underlying math (e.g., hours missed multiplied by the hourly wage). This is a non-responsive answer and will likely draw an objection and a demand for a more complete response. Always break down the calculation clearly to justify the total amount claimed.

When asked to state the facts supporting a claim or defense (e.g., Interrogatory 115.1), parties often provide a legal conclusion like 'The plaintiff was negligent.' This is incorrect; the form requires the specific facts that support that conclusion, such as 'The plaintiff was traveling 20 mph over the speed limit and did not stop at the stop sign.' Providing only conclusions is evasive and will require you to amend your answers later. Focus on describing what happened, not the legal label for it.

Instruction 3(e) allows you to answer an interrogatory by referring to a document, but it requires you to specify the page and section where the answer can be found. A common error is to write 'See attached medical records' and attach a hundred-page file, which is improper. This forces the other party to hunt for the information and can result in a motion to compel a more specific answer. If you reference a document, you must provide a pinpoint citation to the exact location of the answer.

Interrogatory 110.1 asks about any other injuries involving the 'same part of your body claimed to have been injured in the INCIDENT.' People sometimes omit prior or subsequent injuries, either by accident or intentionally, hoping to strengthen their case. This is a critical mistake that can destroy a party's credibility if uncovered. It is essential to be completely transparent and list all relevant medical history as requested to avoid accusations of hiding evidence.

Numerous interrogatories require the name, ADDRESS, and telephone number for individuals like witnesses (112.1), health care providers (106.3), and employers (102.5). A frequent error is providing only a name or an incomplete address without a zip code or phone number. This is an incomplete response that hinders the other party's ability to conduct their investigation. To avoid this, ensure you provide the full, correct contact details for every person identified in your answers. AI-powered tools like Instafill.ai can help by auto-completing and validating addresses to prevent such errors.

This mistake is made by the party sending the form. According to Instruction 2(d), the asking party must check the box next to each interrogatory they want answered. Sometimes, a party serves the form without checking any boxes, leaving the answering party unsure of what questions to respond to. This renders the discovery request defective and will require the asking party to re-serve it correctly, wasting time and resources. Since this form is a non-fillable PDF, a tool like Instafill.ai can convert it into an interactive version, making it easier to check the required boxes and avoid this simple but costly error.