Special Interrogatories are similar to Requests for Admission in that you get to formulate your own questions that the opposing party must answer. However, instead of asking for essentially a yes or a no, you are asking an open ended question. While Requests for Admission are incredibly useful at narrowing the issues of the case, Special Interrogatories are best used to develop the underlying facts that the opposing party is relying upon for their defense.
For that reason, when utilizing Special Interrogatories, you want to be certain that the opposing party gives you as much information as useful, but you don’t want to make the question so broad that the opposing party can properly answer your question by giving you an unusable data dump.
The best way to do this is to think about what specific information you are requesting and to formulate a question that gets the information. You then want to objectively answer the question as if you are the opposing party and attempt to either not answer the question or include as much extraneous detail as possible that doesn’t go to what you want but technically answers the question. While this exercise can be very time consuming, it can also ensure that you will have the best questions that you possibly can have going to your opponent.