§ 9-11-33.Interrogatories to parties

Interrogatories go out without leave of court — on the plaintiff once the action commences, and on any other party with or after service of the summons and complaint. A corporate or governmental party answers through whichever officer or agent can supply the available information. The hard cap on a set of interrogatories served without court permission is 50, subparts included; going beyond that requires leave of court, granted on a showing of complex litigation or the undue hardship that would result if the extra interrogatories weren’t allowed.

Each interrogatory gets a separate, complete answer under oath, or a stated objection in its place, with answers signed by the person who made them and objections signed by the attorney raising them. The response window is 30 days after the interrogatories are served, but a defendant gets a floor of 45 days measured from service of the summons and complaint — not from service of the interrogatories themselves — and the court can shorten or lengthen either deadline.

Interrogatories reach anything within the chapter’s general discovery scope, and one isn’t objectionable just because answering it calls for an opinion or a contention about fact or the application of law to fact — though the court can put off that kind of answer until later discovery, or a pretrial conference, if it prefers.

When the answer can be pulled from the responding party’s own business records, and both sides would face about the same amount of work extracting it, the responding party can point to those records instead of writing out an answer, so long as it gives the requesting party a reasonable opportunity to examine, audit, inspect, copy, compile, and summarize from them.