Rule 33.Interrogatories to parties.
Last amended July 1, 2018 · Last verified July 1, 2026
Full Text of Rule 33
Amendment History
Promulgated by R-16-0010, effective January 1, 2017; amended by R-17-0010, effective July 1, 2018.
Plain-English Summary
Interrogatories are written questions that one party serves on another and that the responding party must answer in writing, under oath, within the deadline the rule sets. How many interrogatories a side may serve is not left open-ended: Rule 26.2 assigns each case to a discovery tier, and that tier caps the number of interrogatories, with a procedure in Rule 26.2(g) and (h) for asking the court to allow more when the case needs it.
An interrogatory is not off-limits merely because it calls for an opinion or asks the responding party to apply the law to the facts, though the court can defer answers to that kind of contention interrogatory until later in the case. Objections must spell out their grounds with enough detail to let the requesting party and the court evaluate them, and an unstated objection is generally waived. Rule 84's uniform interrogatory forms give parties a ready-made, presumptively proper set of questions for common types of cases.
When the answer to an interrogatory can be found by digging through business records, and the burden of that search would fall equally on either side, Rule 33(d) lets the responding party point to the records instead of writing out a narrative answer, provided it identifies the records specifically enough that the requesting party can find them just as easily.
Frequently Asked Questions
How many interrogatories can a party serve?
The limit depends on the case's discovery tier under Rule 26.2, which sets a specific number for each tier. A party who needs more can seek the other side's agreement or ask the court for permission to exceed the limit.
Can a party object to an interrogatory instead of answering it?
Yes, but the objection has to state its grounds specifically, and any part of the interrogatory that is not objectionable still has to be answered.
Can a company answer interrogatories through business records instead of writing out answers?
When the answer can be worked out from the responding party's business records and the research burden would be about the same for either side, the responding party may identify the records in enough detail for the requesting party to locate them and let that party do the digging.