Interrogatories

  • Governed by Rule 33.
  • A party may serve on any other party no more than 25 written interrogatories, including all discrete subparts.
    • Responding party must answer in writing and under oath.
  • Ways to get more interrogatories:
    • Going to the court and asking for more
      • Scope of Case is too large, etc....
    • Stipulation by Opposing Counsel
      • Opposing counsel grants, interrogatories increase—usually part of a trade.
  • When would you use interrogatories?
    • To figure out what to request in a Rule 34 Request for Production
    • To use a cheaper discovery tool
    • When you need the opposing party to do research under legal authority/obligation for you.
  • Why wouldn't you use interrogatories?
    • You can't ask follow up questions if you've exhausted all of your interrogatories.