Massachusetts Agreed Order Granting Additional Time to Plead and Respond to Interrogatories and Requests for Production

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Agreed Order Granting Additional Time to Plead and Respond to Interrogatories and Requests for Production

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FAQ

The plaintiff may mail you a package of questions about your case. These are called Interrogatories. You must answer the questions within 45 days.

Rule 33 of the Federal Rules of Civil Procedure limits the number of interrogatories a party may propound to twenty-five. Parties must obtain leave of court before serving more than twenty- five interrogatories.

Rule 26(c), which substantially copies Federal Rule 26(c), provides the mechanism by which a person (whether party or not) from whom discovery is sought may obtain court relief in the event he believes he is being unfairly oppressed. Generally, the order will be sought in the court in which the action is pending.

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.

Method of Service and Due Date of Responses Unless otherwise ordered by the court, responses to requests for production or inspection are due within thirty (30) days of service of the request. A defendant may serve a response within forty-five (45) days after service of the summons and complaint upon that defendant.

You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.

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.

Has anyone ever heard of the 33% rule? It basically states that 33% of your time should be spent with mentors (people that challenge you), 33% with your peers (those on the same level as you), and 33% with people that you can mentor and guide.

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Massachusetts Agreed Order Granting Additional Time to Plead and Respond to Interrogatories and Requests for Production