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Unless otherwise stipulated or ordered by the court, a party may serve on any other party no more than 40 written interrogatories, including all discrete subparts.
Rule 33(d) states that a party electing to respond to an interrogatory by providing electronically stored information must ensure that the interrogating party can locate and identify it ?as readily as can the party served,? and that the responding party must give the interrogating party a ?reasonable opportunity to ...
You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.
Each interrogatory must, to the extent it is not objected to, be answered separately and fully in writing under oath. Answers and objections to interrogatories must identify and quote each interrogatory in full immediately preceding the answer or objection.
What types of questions can I ask in interrogatories? Questions about the other party's position or arguments in the case. Questions about the facts of the case. Questions about the other party's knowledge or understanding of relevant events or circumstances. Questions about the other party's witnesses or experts.
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.