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Interrogatories are a discovery tool that the parties can use to have specific questions about a case answered before trial. Interrogatories are lists of questions sent to the other party that s/he must respond to in writing.
Answer. Requests for the Production of Documents. Definition: A written list of documents, electronic files, and audio and video recordings or physical things, submitted to a party from his or her adversary to inspect and copy the requested items and that have relevance to the issues in a lawsuit.
2030.020. (a) A defendant may propound interrogatories to a party to the action without leave of court at any time. (b) A plaintiff may propound interrogatories to a party without leave of court at any time that is 10 days after the service of the summons on, or appearance by, that party, whichever occurs first.
Common objections to requests for production or inspection include: The request is overly broad or unduly burdensome. ... The request is vague, ambiguous, or unintelligible. ... The request is not reasonably calculated to lead to the discovery of relevant, admissible evidence.
Interrogatories, which are written questions about things that are relevant or important to the case. (NRCP 33; JCRCP 33) Requests for production of documents or things, which are written requests that demand the other side provide particular documents or items.
Each interrogatory must, to the extent it is not objected to, be answered separately and fully in writing under oath. The grounds for objecting to an interrogatory must be stated with specificity. Any ground not stated in a timely objection is waived unless the court, for good cause, excuses the failure.
A request for production occurs when one party asks another to procure ESI or physical evidence. For example, this may include emails, photographs, text messages, charts, or graphs. On the other hand, physical evidence may encompass items like paper and gifted objects.
(2) Production of documents. In addition to document disclosures required under rule 1.500(1)(a), each side may serve no more than 10 requests for production on any other side under rule 1.512.