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(2) Interrogatories. Each party may serve no more than 25 written interrogatories, excluding interrogatories asking a party only to identify or authenticate specific documents. Each discrete subpart of an interrogatory is considered a separate interrogatory.
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.
The Special Interrogatories you received should have a list of numbered questions. You need to respond to each question in the same order on your response template. On your template, each question, write ?Response to Interrogatory number? followed by the number of the question.
You should respond to each interrogatory in the order received. Start by retyping each interrogatory and then follow each question with your answer. If an answer comes from information you received from other people, you should write that as part of your response. Your answers must be signed under oath.
You are limited to 30 interrogatories per party in the case, unless a written stipulation is reached or the court authorizes. There is a statutory procedure for requesting additional interrogatories, and this procedure must be followed before the additional requests are made.
Also, your Answer to Interrogatories must be sworn. That is, you need to attach a verification page and notarize the document. This means that you are attesting that your answers to the questions are true and correct to the best of your knowledge.
The discovery rule is a ?narrow exception? to the legal injury rule that ?defers accrual of a cause of action until the plaintiff knew or, exercising reasonable diligence, should have known of the facts giving rise to the cause of action.? Berry, 646 S.W.
In contrast to interrogatories and requests for admission, which are limited to 35 questions as a "matter of right", there is no limit on demands for production.