Draft interrogatories should be drafted as:

They should be drafted as questions to be answered

They must be written as statements rather than questions

Draft as imperative statements

Draft interrogatories as imperative statements because the purpose is to compel specific, sworn information from the other party. Framing each item as a direct command—telling the respondent to provide particular facts or documents—creates a clear, enforceable duty to answer. This imperative style promotes precise, complete responses that can be recorded under oath and used later in litigation. It also helps keep the discovery record organized and unambiguous, since each item is a standalone directive that drives a targeted answer. Writing interrogatories as simple questions can invite guarded or partial responses, while pure statements lack the required force to prompt an answer. Exclamations are inappropriate for formal legal drafting.

They should be written as exclamations

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