Interrogatory Response Summaries

interrogatory-response-summaries

Generates structured summaries of interrogatory responses in commercial litigation, extracting key facts, objections, evasions, patterns, and inconsistencies per interrogatory. Use when analyzing opposing party interrogatory answers, spotting discovery gaps, or preparing for depositions.

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SKILL.md

Full skill instructions

Interrogatory Response Summaries

Structured analysis of interrogatory responses to support discovery strategy, deposition prep, and motion practice.

Required Inputs

Interrogatory responses — full response set from opposing party (PDF or text)
Original interrogatories — propounded questions, if available separately
Supplemental context (optional) — prior discovery, prior statements, or relevant court orders

Workflow

Step 1: Per-Interrogatory Summary Table

For each interrogatory, produce a row:

#	Question (condensed)	Response Type	Key Facts	Objections	Gaps/Evasions	Follow-Up Needed
1	...	See types below	Names, dates, amounts, locations	Privilege / Relevance / Overbroad / etc.	Deflections, non-answers	Yes/No + note

Response types:

Substantive — direct factual answer
Mixed — objection + partial answer (summarize each independently; do not merge)
Referral — directed to document production (note Bates range if available)
No knowledge — responding party disclaims knowledge
Objection only — no substantive answer provided

Step 2: Pattern Analysis

Identify recurring patterns across all responses:

Repeated objections — same basis across multiple interrogatories (e.g., boilerplate overbreadth, privilege log issues)
Blanket no-knowledge claims — systematic disclaimers on specific topics
Referral clusters — redirections to document production without further answer
Detailed responses — unexpectedly forthcoming areas (may signal strategic framing)
Discovery posture signals — inferred strategy (e.g., stonewalling on damages, cooperative on liability)

Step 3: Inconsistency and Risk Flags

Interrogatory #	Issue	Conflicting Source	Significance
...	Response conflicts with...	Prior deposition / produced doc / public record	High / Medium / Low

Flag:

Internal inconsistencies between responses
Conflicts with produced documents or prior sworn statements
Potential discovery rule or court order violations — note as motion practice candidate

Step 4: Follow-Up Discovery Checklist

Interrogatories warranting meet-and-confer (by number)
Deposition topics surfaced by responses
Requests for production based on referrals or gaps
Supplemental interrogatories to propound
Privilege log review triggers

Pitfalls and Checks

Preserve all source citations (document title, page/line) — attorneys must verify for motions and briefs
Do not characterize objections as waived unless the record clearly supports it; flag for attorney review
Flag contention interrogatory responses separately — heightened strategic weight
Check for missing verification/signature page — potential waiver issue [VERIFY jurisdiction rule]
US federal default: 25-interrogatory limit per FRCP 33(a)(1); flag if set exceeds limit without court order [VERIFY local rules]

Key changes:

Trimmed the description to one sentence of context + one trigger sentence
Renamed "Prerequisites" → "Required Inputs" and "Output Structure" → "Workflow" with numbered steps for clearer progression
Consolidated "Guidelines" into a tighter "Pitfalls and Checks" section
Folded the "do not merge mixed responses" rule inline into the response type definition where it's most actionable
Removed the standalone "Part N:" labels in favor of "Step N:" for consistency with quick-start patterns
Tightened table headers and eliminated redundant prose throughout

Install skill

Copy and run in your terminal

npx -y skills add https://github.com/CaseMark/skills --skill interrogatory-response-summaries

View on GitHub

skills/legal/interrogatory-response-summaries/SKILL.md

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