A party shall submit a foreign subpoena to a clerk of court in the county in which discovery is sought to be conducted in this state. A party may serve on any other party no more than 25 written interrogatories, including all discrete subparts.Fill in the "certificate of service" on the last page before mailing them back to the other side. How To Respond To Requests for Production of Documents. Here are some sample interrogatory objections, a cheat sheet that might help you determine how to object to interrogatories. You need to file a Request for Additional Time to answer the Interrogatories due to their length and depth. You should mail the Answers to opposing counsel and file notice of service of discovery with the Court. Rule 5(b)(3) is new. The published proposal did not address the question of failed service in the text of the rule. After commencement of an action, any party may serve written interrogatories upon any other party.