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WPI 6.10 Use of Interrogatories of a Party

6 WAPRAC WPI 6.10Washington Practice Series TMWashington Pattern Jury Instructions--Civil

6 Wash. Prac., Wash. Pattern Jury Instr. Civ. WPI 6.10 (7th ed.)
Washington Practice Series TM
Washington Pattern Jury Instructions--Civil
April 2022 Update
Washington State Supreme Court Committee on Jury Instructions
Part I. General Instructions
Chapter 6. Oral Instructions During Trial
WPI 6.10 Use of Interrogatories of a Party
You will now be given evidence in the form of answers to written interrogatories. Interrogatories are questions asked in writing by one party and directed to another party. The answers to interrogatories are given in writing, under oath, before trial.
The answers to interrogatories will be [read aloud] [presented] to you. Insofar as possible, give them the same consideration that you would give to answers of a witness testifying from the witness stand.
Use this oral instruction before interrogatories and answers are read to the jury. The attorney offering the evidence should “inform” the judge ahead of time and give the judge an opportunity to give this oral instruction. This oral instruction is not appropriate if answers to interrogatories are being used for impeachment only.
Do not use this instruction for requests for admission under CR 36. The effect of requests for admission under the rule is not the same as the introduction of evidence through interrogatories. If an instruction is needed, refer to WPI 6.10.01 (Stipulations) or 6.10.02 (Use of Admissions or Binding Stipulations Under CR 36(b)).
CR 33(b). The court rule allows interrogatories to be used at trial.
[Current as of November 2020.]
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