Yes! You can use AI to fill out Form Interrogatories—General

Users often enter the wrong case number, misspell party names, or leave the 'Short Title of Case' field incomplete. This typically happens due to carelessness or not having the correct court documents on hand for reference. Such errors can cause the filing to be rejected by the court clerk or lead to significant confusion and delays in the legal process. To avoid this, always cross-reference the information with the official Summons or Complaint; if the form is a non-fillable PDF, a tool like Instafill.ai can convert it to a fillable version and help ensure case data is consistent across all documents.

A critical and frequent mistake is forgetting to sign and date the verification statement required by Section 3(h), which attests that the answers are true under penalty of perjury. This often occurs because the signature block is at the very end of a long document. Unverified responses are legally invalid and treated as if no answer was provided, which can lead to sanctions or a motion to compel from the opposing party. Always perform a final check for the signature and date before serving the responses.

Parties often provide non-responsive answers like 'See complaint,' 'Investigation ongoing,' or 'The document speaks for itself' instead of the specific facts required. This violates the duty under Section 3(c) to answer as completely and straightforwardly as possible with all reasonably available information. These evasive tactics almost always result in deficiency letters and costly, time-consuming motions to compel, and they can damage your credibility with the court.

The form defines terms like 'INCIDENT,' 'DOCUMENT,' and 'YOU OR ANYONE ACTING ON YOUR BEHALF' in Section 4, but filers often fail to read or apply these definitions. For example, a user might narrowly interpret 'DOCUMENT' as only paper files, forgetting to include required electronically stored information like emails, texts, and digital photos. This leads to incomplete and inaccurate responses, potentially resulting in sanctions for failure to disclose.

Questions in Section 2.0 and 11.0 demand historical data like five years of residence addresses or ten years of prior personal injury claims. People frequently provide incomplete lists by relying on memory alone, which can be used later to attack their credibility. Before answering, it is crucial to gather personal records, old resumes, and legal files to ensure every required item is listed accurately and completely.

Many interrogatories (e.g., 2.13, 15.1) are divided into multiple subparts (a, b, c, etc.) that request distinct pieces of information. A common error is to answer the main question but neglect to address each individual subpart, rendering the entire response incomplete. This forces the asking party to file a motion to compel, wasting time and money for both sides. Carefully read and respond to every single subpart of a checked question.

When objecting to a question, parties often write a generic 'Objection' or 'Privileged' without stating the specific legal basis as required by Section 3(g). An improper objection is legally ineffective and can be deemed waived by the court, forcing the party to answer the question anyway. Objections must specifically state the grounds, such as 'Objection, the question calls for information protected by the attorney-client privilege.'

Interrogatory 1.1 requires listing every person who helped prepare the answers, but filers often forget to include investigators, accountants, or even family members who helped gather information. This omission can be problematic, as the opposing party is entitled to know who contributed to the factual basis of the responses. To avoid this, keep a log of everyone you consult and list them accurately as required.

Section 3(e) allows a party to answer by referencing a document, but many people make the mistake of attaching a large exhibit without specifying the exact page and section where the answer is located. This makes the answer non-compliant and forces the other party to search for the information. When referencing a document, you must provide a precise citation (e.g., 'See Exhibit A, page 5, paragraph 3') to guide the reader to the exact answer.

The form repeatedly asks for the name, ADDRESS, and telephone number for individuals like witnesses (12.1), employers (2.6), and doctors (6.4). A frequent error is providing only a name, which is insufficient. This happens when the information isn't readily available, but Section 3(d) requires a good faith effort to obtain it. AI-powered tools like Instafill.ai can help prevent this by validating address and phone number formats, reminding you to fill in all required fields for a complete and compliant response.