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If your case is an unlimited civil case (over $25,000) you may ask up to 35 special interrogatories, but may ask more with a declaration explaining the need for additional requests and a statement that the request is not done for an improper purpose.
Interrogatories Need to Be Written Carefully Identify the geographic locations for the product market alleged in paragraph 16 of the Complaint. Identify each customer you directly or indirectly solicited to purchase the product. Identify any terms you used to describe potential purchasers of the product. For the second:
The interrogatories must not exceed 30, including all subparts, unless the court permits a larger number on motion and notice and for good cause.
Reading section 30 with Order XI Rule 1 of the Code, it makes clear that the courts have the discretion to allow service on interrogatories at any stage of the suit. The court confers wide discretion, at the same time the discretion shall be exercised judiciously.
No party shall serve on any other party as of right more than one set of interrogatories, unless the total number of all interrogatories in all sets combined does not exceed thirty; including interrogatories subsidiary or incidental to, or dependent upon, other interrogatories, and however the same may be grouped or ...