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(1) Number. 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. Leave to serve additional interrogatories may be granted to the extent consistent with Rule 26(b)(1) and (2).
In California, if a witness is a non-party i.e., not a party to the action or a party- affiliated witness a deposition subpoena must be served to compel that witness's attendance, testimony, or production of documents and things pursuant to Chapter 6, Nonparty Discovery, of the CDA, Cal. Civ.
You must answer each interrogatory separately and fully in writing under oath, unless you object to it. You must explain why you object. You must sign your answers and objections.
The number of questions included in an interrogatory is usually limited by court rule. For example, under the Federal Rules of Civil Procedure, each party may only ask each other party 25 questions via interrogatory unless the court gives permission to ask more.
Contention interrogatories are authorized pursuant to Federal Rule of Civil Procedure 33. Contention interrogatories can be characterized as: any question that asks another party to indicate what it contends . . . a question asking another party whether it makes some specified contention . . .
You must answer each interrogatory separately and fully in writing under oath, unless you object to it. You must explain why you object. You must sign your answers and objections.
Language permits a party to serve interrogatories only on other parties.Second, and in any event, Rule 45 does not permit a party to use a subpoena to obtain information from non-parties that is unrelated to the action in which the Rule 45 subpoena is issued.
Interrogatory subparts are counted as one interrogatory if they are logically or factually subsumed within and necessarily related to the primary question. Safeco of America v. Rawstron, 181 F.R.D. 441, 445 (C.D. Cal.
The interrogatories shall not exceed 30, including all subparts, unless the court permits a larger number on motion and notice and for good cause.