State your residence addresses for the past five years up to the present time, indicating periods of residence at each address. 1. Except as otherwise provided herein, after commencement of an action, any party may serve upon any other party written interrogatories.Service of interrogatories. After commencement of an action, any party may serve written interrogatories upon any other party. (d) Service of Interrogatories: Plaintiff:______ Defendant:______. Interrogatories are a discovery tool (among many) used in lawsuits in New York courts. In sum, these are written questions seeking specific information. Rule 4(b): Interrogatory answers are due 60 days after service. The procedures to obtain discovery in Texas for an outofstate proceeding remain as generally discussed in the older article below. This article's purpose is to provide a guide for properly responding (and objecting) to interrogatories and production requests under the Texas.