Interrogatories PDF to Word: Drafting Responses From a Scan

To move scanned interrogatories from PDF to Word, run the PDF through OCR, export a Word file, and then check every interrogatory number and every word of each question against the scan before you type a response under it. Ask opposing counsel for the Word version as well. Some courts' rules entitle you to it.

The reason for the care is that a response set which repeats each question above its answer carries any misquote into your own signed paper. This post walks through the conversion, the numbering, the front matter, and the other request types that arrive in the same envelope. It explains document handling and is not legal advice. Response formats and deadlines differ by court.

Why do served interrogatories arrive as a scan?

Served interrogatories arrive as a scan because of how they were signed and sent. The serving lawyer printed the document, signed it in ink, and ran the signed copy through the office copier to make the service copy. What reaches you is a picture of each page, even though a Word file exists on the sender's computer.

Other routes lead to the same place:

• Paper service. The set came by mail or by hand, and your own mailroom scanned it into the matter.
• A printed form. If the set is a pre-printed form with check boxes, the sender ticked the boxes by hand and scanned the result.
• Fax. Coarse resolution and a header line across the top of every page.
• A forwarded copy. The client was served directly, photographed the pages on a phone and emailed them to you.
• A flattened PDF. The sender printed to PDF through a driver that stored page images, so the file looks typed and still has no selectable text.

Not every served PDF is a scan. Before converting, try to select a sentence. If words highlight, the file has real text and you can copy from it or open it directly in a word processor, which is quicker and exact. The quick tests are in the post on why you can't copy text from a PDF.

One thing to do on the day the set arrives, before any conversion: record the service date and method. In federal court a responding party "must serve its answers and any objections within 30 days after being served with the interrogatories" under Rule 33(b)(2) of the Federal Rules of Civil Procedure, unless a stipulation or order sets a different time. State deadlines differ. The date goes on the calendar from the served paper, and the lawyer confirms it.

Converting served interrogatories to an editable Word file

Keep the served PDF untouched, convert a copy to Word, and build your response document from the converted text only after you have compared it with the scan. Expect clean results on typed pages and trouble at the caption, the margins and the signature block.

1. File the served copy as received. Name it with the serving party, the set number and the service date. Nobody edits this file.
2. Check the page count. A set that jumps from Interrogatory No. 11 to No. 14 may be missing a page from the scan, not from the request.
3. Convert a copy. In Schema Law you sign in, upload the PDF in your browser and wait for the pages to be read. Uploads can be PDF, PNG or JPEG up to 20 MB. Word export is included on every plan, and the free plan handles one document a day of up to three pages, so a longer set needs a paid plan or another tool. The pricing page has the page limits.
4. Export to Word and save it as a conversion copy. Do not draft in this file yet.
5. Strip what is not the requests. Line numbers, footers, page numbers and fax headers. On line-numbered paper the margin digits get mixed into the questions; the section on line-numbered pleading paper explains how to remove them safely.
6. Proofread each interrogatory against the scan. Read the question on the image, then the converted text. Dates, dollar figures, defined terms in capitals and the word "not" get a second look.
7. Paste the checked questions into your firm's response template as plain text, so the sender's fonts and odd spacing stay behind.
8. Add the response structure. Under each question, a heading for the response and space for objections.

General points about what a scan turns into in Word, and what to check before editing any converted file, are in the guide on how to convert a scanned PDF to Word.

What the response has to look like

Check your court's format rule before you design the template, because some courts require the question to be reproduced. The District of New Jersey's Local Civil Rule 33.1 says the answering party "shall repeat each question, including subparts, in full immediately prior to each corresponding answer." The Southern District of Indiana's Local Rule 26-1 requires a responding party to "fully quote each interrogatory or request immediately before each response and number each response to correspond." Rules like those are why the converted text has to be exact. It ends up in your document over your signature.

How do you keep interrogatory numbering exact after conversion?

Type the numbers yourself, as plain text, and check them against the scan one at a time. Do not let Word number the questions automatically. A converted list can renumber itself the moment you delete a line, and then your Response to Interrogatory No. 9 answers the other side's No. 10.

What goes wrong with numbers in conversion:

• Automatic lists. The export or Word itself turns "1." and "2." into a live numbered list. Delete the definitions section above and every number shifts.
• Misread digits. "8" comes back as "3" or "B", "11" as "ll", "1" as "l". The post on why OCR gets numbers wrong covers these confusions.
• Lost subparts. "(a)", "(b)" and "(c)" lose their indent and merge into the paragraph, or "(c)" becomes a copyright sign.
• A skipped or doubled number in the original. The sender numbered two questions 14, or went from 16 to 18. That is their numbering and you answer to it as served.
• Numbering that continues from an earlier set. A second set may start at No. 26. Do not restart at 1.

A routine that catches all of these:

1. Select the whole converted document and convert automatic numbering to fixed text, or paste as plain text into a new file, before you remove anything.
2. Write down the first and last interrogatory numbers and the total from the scan.
3. Search the Word file for "INTERROGATORY NO." and count the hits. The count should match.
4. Walk the list once with the scan open, ticking each number and its subparts.
5. Leave any error in the sender's numbering alone, and tell the lawyer, who may want to note it in the response.

Counting matters for another reason. Federal Rule 33(a)(1) limits a party to "no more than 25 written interrogatories, including all discrete subparts" unless the parties stipulate or the court orders otherwise. Whether a set goes over is a legal judgment about what counts as a discrete subpart. A clean, correctly numbered Word copy with every subpart on its own line is what lets the lawyer make it.

Definitions and instructions sections in a discovery request

Keep the whole definitions and instructions section in your conversion copy and proofread it, because it controls what each question means. Leave it out of the response document unless your court's format calls for it. The lawyer decides which definitions and instructions to object to, and needs accurate text to do that.

A set of interrogatories often opens with several pages before the first question: definitions of "you", "document", "communication", "identify" and "relating to", then instructions on time period, privilege claims and supplementation. Those pages change the reach of every question. "Identify all communications" asks for one thing with a narrow definition of "identify" and a great deal more with a broad one.

For conversion, that means:

• Proofread defined terms with care. A definition that reads "the Agreement dated March 3, 2021" must carry the right date, since every question that says "the Agreement" depends on it.
• Keep capitals as served. A capitalized "Property" and a lower-case "property" may be different things in the set.
• Keep the section's own numbering. Objections to definitions can cite them by number: "Defendant objects to Definition No. 4."
• Note the stated time period. Look for it in the instructions, because it frames every answer.

Some courts take part of this off the page. In the Southern and Eastern Districts of New York, Local Civil Rule 26.3 provides uniform definitions that are "deemed incorporated by reference into all discovery requests", and says no request may use broader definitions than those. Where a rule like that applies, the lawyer will want the served definitions side by side with the rule's. Your accurate conversion copy is one half of that comparison.

What you can cut from the response document: the caption as scanned (your template has its own), the sender's signature block, the certificate of service for their set, and page furniture. What you never cut from the conversion copy: anything.

Paste each interrogatory with its answer when you move the discovery response into Word. The question number has to stay attached to the paragraph you are editing. If the response objects and also answers, leave both parts in that block. Proof the party names against the served scan before the response goes out.

Requests for production and requests for admission from the same scan

Requests for production and requests for admission convert the same way as interrogatories, but each has its own numbering series and its own response format. Split the scan into one Word file per request type before drafting, and keep each series exactly as served.

A sender may serve all three together, sometimes in one PDF. The first job is to find the boundaries: each set has its own title, its own definitions and its own run of numbers starting again at 1.

Three points on the differences.

Requests for admission need the closest proofread. Under Rule 36(a)(4), an answer that does not admit a matter "must specifically deny it or state in detail why the answering party cannot truthfully admit or deny it." A request that says "on or before June 1" and a converted copy that says "on or before June 7" are different matters. The same rule sets a consequence for missing the deadline: under Rule 36(a)(3), "a matter is admitted unless, within 30 days after being served," the party serves a written answer or objection, subject to any stipulation or order. Calendar the admissions on the day they arrive.

Attached documents stay as images. Rule 36(a)(2) says a request to admit the genuineness of a document "must be accompanied by a copy of the document" unless it has been otherwise furnished. Those exhibit pages at the back of the scan are not text to convert into your response. Keep them with the served copy and refer to them by the sender's exhibit labels.

Requests for production set up the next job. A response under Rule 34(b)(2)(B) must, for each item or category, state that inspection will be permitted as requested, or that copies will be produced instead, or "state with specificity the grounds for objecting to the request, including the reasons." Once the categories are in Word you can turn them into a checklist for collecting documents. If what you collect is paper, the guide on how to produce scanned documents in discovery picks up from there.

The verification page

Interrogatory answers end with a verification, and it is often the one handwritten page in the set. Federal Rule 33(b)(3) requires each interrogatory, to the extent not objected to, to be "answered separately and fully in writing under oath", and Rule 33(b)(5) says "the person who makes the answers must sign them, and the attorney who objects must sign any objections." When the other side's answers come back with a hand-signed or hand-completed verification, treat that page as an image to keep. What OCR does with handwritten sworn pages is covered in the post on OCR for a handwritten affidavit.

Should you ask opposing counsel for the Word version instead?

Yes, ask, and convert the scan anyway while you wait. A Word file from the sender is the exact text with no recognition errors, and in some courts the sender must provide it on request. A request costs one short email. The deadline keeps running whether or not anyone replies.

Some local rules make it an entitlement. The Southern District of Indiana's Local Rule 26-1 requires a party propounding written discovery under Rules 33, 34 or 36 to, "upon request, supply the written discovery to the responding party in an editable word processing format." The District of New Jersey's Local Civil Rule 33.1 says that, upon request, interrogatories "shall be provided in electronic word processing format for ease of answering if technologically feasible." Not every court has such a rule, and state practice varies, so check your own. Where there is no rule, it is a courtesy you can ask for and may be asked for in return.

A request can be two sentences: "We received Plaintiff's First Set of Interrogatories, served by mail on [date]. Please send the set in Word format so that we can reproduce each interrogatory in our responses."

If the Word file arrives, do three things before relying on it:

1. Compare it with the served scan. The served paper is the operative set. A Word file can be an earlier draft with a question the sender later changed. Read the numbers, count the questions and spot-check the wording.
2. Clear the file's history. Accept or reject tracked changes and delete comments in your copy, so none of the sender's markup travels into your response.
3. Paste as plain text into your own template. Their styles and automatic numbering are the same hazard as a converted list.

And if it does not arrive, you have lost nothing, because the converted copy is already proofread. On a short set of a dozen questions, a careful conversion and check takes less time than the exchange of emails. On three sets with forty requests each, the sender's file saves real work. Either way the comparison against the served scan is the step that protects you, and the three-step upload and export process on the Schema Law homepage shows how little of the job the conversion itself is.