We can't really answer these questions here as there are so many factors. For example, we don't know the response dates for the interrogatories. There should be one. I also don't understand how you can serve a response to interrogatories (questions) after a trial. After all, your responses are supposed to be useful IN trial so that the other side can review and ask questions. As to delays, the parties can negotiate on adjournments. It all depends upon the specific set of facts.