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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 ...
(a) In General. (1) Number. Unless otherwise stipulated or ordered by the court for good cause allowing a specific additional number of interrogatories, a party may serve on any other party no more than 40 written interrogatories, including all discrete subparts.
You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.
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.
Unless otherwise stipulated or ordered by the court, a party may serve on any other party no more than 25 written interrogatories, including all discrete subparts.
(B) Protection Against Disclosure. If the court orders discovery of those materials, it must protect against disclosure of the mental impressions, conclusions, opinions, or legal theories of a party's attorney or other representative concerning the litigation.
Rule 33(a), Federal Rules of Civil Procedure, restricts to 25 (including all discrete subparts) the number of interrogatories a party may serve on any other party. Leave of court, which is not routinely given absent stipulation, is required to serve more than 25 interrogatories cumulatively.
You must answer the questions or file objections to certain questions or the entire set of interrogatories. For example, you might not want to answer a question because it contains incorrect information like asking you to state who treated your broken leg, but you did not break your leg.