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Identify each ADVERSE EMPLOYMENT. Rule 33, as amended, permits either interrogatories after a deposition or a deposition after interrogatories.Defendant, LDI MECHANICAL, INC. ONE. This section discusses technical requirements for interrogatories in FEHA cases and provides sample special and form interrogatories. Interrogatory Requirements. Generally, written discovery is a party's first opportunity to seek information regarding the opposing side's claims or defenses. Code of Civil Procedure section 2020. 2030.020. (a) A defendant may propound interrogatories to a party to the action without leave of court at any time. (c) The judge has personal knowledge of disputed evidentiary facts concerning the proceeding. This information can then be used at trial.