Rule 21. Interrogatories to Parties

Availability; Number. Any party may serve upon any other party written interrogatories to be answered by the party served. Unless the parties stipulate under Rule 22 or the court orders otherwise, no party shall serve upon any other party more than fifteen (15) written interrogatories, including all discrete subparts. Leave to serve additional interrogatories may be granted to the extent consistent with Rule 19(2) and Rule 19(3).

Scope. An interrogatory may relate to any matter that may be inquired into under Rule 19(2). An interrogatory is not objectionable merely because it asks for an opinion or contention that relates to fact or the application of law to fact, but the court may order that such an interrogatory need not be answered until designated discovery is complete, until the pre-trial conference under Rule 13, or until some other time.

Form. Each interrogatory shall be stated separately and numbered consecutively throughout the action, so that a later set continues the numbering of an earlier set. An interrogatory shall not incorporate by reference a definition or instruction so extensive that the interrogatory cannot be understood as written.

Responding Party. The interrogatories shall be answered by the party to whom they are directed or, if that party is a corporation, partnership, association, business entity, or governmental agency or department, by any officer or agent, who shall furnish the information available to the party. An answer shall include information within the knowledge of the party’s agents, employees, and attorneys, and information the party has the practical ability to obtain.

Time to Respond. The responding party shall serve its answers and any objections within forty-eight (48) hours after being served with the interrogatories. A shorter or longer time may be stipulated to under Rule 22 or ordered by the court, but no stipulation shall extend the time beyond the close of the pre-trial period allowed by Rule 6(1) without leave of court.

Answering Each Interrogatory. Each interrogatory shall, to the extent it is not objected to, be answered separately and fully in writing under oath. The oath may be administered by a notary public commissioned under 3 R. Stat. §§ 312.001–312.010 and authorized by 3 R. Stat. § 312.101(b), by the Clerk of the Superior Court or a deputy clerk as authorized by 3 R. Stat. § 131.104, or by the judge presiding in the action. A solemn affirmation under the penalties of perjury may be accepted in lieu of an oath.

Objections. The grounds for objecting to an interrogatory shall be stated with specificity. An objection shall state whether any responsive information is being withheld on the basis of that objection. An objection to part of an interrogatory shall specify the part and answer the remainder. Any ground not stated in a timely objection is waived unless the court, for good cause, excuses the failure. A general objection that does not identify the interrogatory to which it is directed and the specific ground on which it rests is of no effect.

Signature. The person who makes the answers shall sign them, and the attorney who objects shall sign the objections. Transmission from the account of that person or attorney constitutes the signature.

Evasive or Incomplete Answers. An evasive or incomplete answer shall be treated as a failure to answer for the purposes of Rule 26.3.

specifying the records that must be reviewed, in sufficient detail to enable the interrogating party to locate and identify them as readily as the responding party could, including the platform, server, channel, conversation, or in-game system in which they reside and the interval of time they cover; and

giving the interrogating party a reasonable opportunity to examine and audit the records and to make copies, compilations, abstracts, or summaries, producing them in the manner Rule 26(5) prescribes.