1959 U. Ill. L.F. 733 (1959)
Interrogatories to Parties and Demands to Admit

handle is hein.journals/unilllr1959 and id is 745 raw text is: INTERROGATORIES TO PARTIES AND
DEMANDS TO ADMIT
BY JOHN K. FEIRICH AND JOHN C. FEIRICH
THIS ARTICLE deals with written interrogatories to parties pursuant to
Illinois Supreme Court Rule 19-11,1 as distinguished from depositions of
witnesses upon written questions as provided for in Supreme Court Rule
19-7,2 and with demands (or requests) for the admission of facts and the
genuineness of documents pursuant to Supreme Court Rule 18.3 Although
almost all the aspects of discovery procedures are closely interrelated, a stren-
uous effort will be made to avoid duplication of other materials in this
symposium, particularly with reference to sanctions and penalties for a
failure to comply with discovery rules 4 and questions of the limitation on
discovery imposed under the doctrine of Hickman v. Taylor 5 with refer-
ence to the lawyer's work product.
INTERROGATORIES TO PARTIES
The adoption of Supreme Court Rule 19-11, as a part of the sweeping
revision of the Civil Practice Act in 1955, established written interrogatories
to parties as a new discovery tool in Illinois, and subsequently they have
become a much-used tool in pre-trial discovery procedures in our practice.
However, only two cases have directly dealt with the question of the use
and scope thereof.7 There being very little law to aid Illinois attorneys in
the interpretation of Rule 19-11, there are hereinafter contained many
references to federal cases decided under Federal Rule 33,8 upon which our
JOHN K. FEIRICH. LL.B. 1933, Chicago-Kent College of Law; mem-
ber of the firm of Feirich & Feirich, Carbondale, Illinois.
JOHN C. FEIRICH. LL.B. 1956, University of Illinois; member of the
firm of Feirich & Feirich, Carbondale, Illinois.
'ILL. REV. STAT. c. 110, S 101.19-11 (1959).
21d. S 101.19-7.
sId. § 101.18.
4 See Note, infra p. 850.
5 329 U.S. 495, 67 Sup. Ct. 385 (1947). See Keegan, Privileged Matters and Pro-
tective Orders, infra p. 801.
6 Interrogatories to parties were used under local court rule in the circuit and
superior courts of Cook County prior to the adoption of Rule 19-11, but were not used
generally elsewhere. See Jenner, Depositions and Discovery Procedures. 44 ILL. B.J. 386
(1956).
7People ex rel. Terry v. Fisher, 12 IMI. 2d 231, 145 N.E.2d 588 (1957); Hruby v.
Chicago Transit Authority, 11 111. 2d 255, 142 N.E.2d 81 (1957).
8 FED. R. Cv. P. 33.

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