Form Discovery

Any who has had a case with me knows I pretty well have everything formed up as far as pleadings.  However, those also have to be tweaked to the particular merits of the case.  I am working on a case now where I am pretty sure the attorney did not read what was sent.  The discovery responses keep asking about the basis for an accident, when there was no accident of any kind that is the subject of the litigation.  The problem with that is that it counts against the number of interrogatories you have and also the response not applicable is a perfectly valid response.  However, I normally try to give opposing counsel the benefit of the doubt on these and supply some kind of answer to redefine their terms a little (i.e. made accident, incident).