This is a sample of a Plaintiff's Motion to propound more than 40 interrogatories on the Defendant and a Motion to Compel responses to earlier discovery requests.
Alabama Motion to Increase Number of Interrogatories
State:
Alabama
Control #:
AL-999A
Format:
Word;
Rich Text
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FAQ
An interrogatory is not objectionable because an answer to it involves an opinion or contention that relates to fact or the application of law to fact, or would be based on information obtained or legal theories developed in anticipation of litigation or in preparation for trial.
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.
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.
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.
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.
So, can you refuse to answer interrogatories? The answer is, no, you may not. You must answer a Rule 33 interrogatory within 30 days of being served with it. That answer must either permit inspection of the requested information or object to the production of the information for a specific reason.
(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).