If a deponent does not have the information with which to answer an interrogatory what must the deponent do to comply with the spirit of the discovery rules?

If a deponent lacks the information necessary to answer an interrogatory, they must provide a reasonable explanation of their inability to answer and make a diligent effort to gather the information. This may include identifying any documents, individuals, or sources that could potentially provide the needed information. Additionally, the deponent should respond to the best of their knowledge and belief, indicating any limitations in their ability to provide a complete answer. Compliance with discovery rules emphasizes transparency and good faith efforts to obtain relevant information.