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Parties may obtain discovery regarding any matter, not privileged, which is relevant to the subject-matter involved in the pending action, whether it relates to the claim or defense of the party seeking discovery or the claim or defense of any other party, including the existence, description, nature, custody, ...
Rule 33(d) states that a party electing to respond to an interrogatory by providing electronically stored information must ensure that the interrogating party can locate and identify it ?as readily as can the party served,? and that the responding party must give the interrogating party a ?reasonable opportunity to ...
No judgment rendered on the motion shall be reversed on the ground that there is a genuine issue of material fact unless the material fact and the evidence relevant thereto shall have been specifically designated to the trial court.
You must answer the questions or file objections to certain questions or the entire set of interrogatories. For example, you might not want to answer a question because it contains incorrect information like asking you to state who treated your broken leg, but you did not break your leg.
(b) A party may discover facts known or opinions held by an expert who has been retained or specially employed by another party in anticipation of litigation or preparation for trial and who is not expected to be called as a witness at trial, only as provided in Rule 35(B) or upon a showing of exceptional circumstances ...
You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.
Any party can serve interrogatories upon another. A party must provide a reasonable space after each interrogatory for a response or objection. The interrogatory being answered (or objected to) must be placed immediately before the answer or objection.