13th Judicial Circuit - Local Rule 32.2

32. Discovery

32.2 Interrogatories

A. Each party shall be limited to propounding a total of thirty (30) interrogatories, including sub-parts thereof, except as provided in paragraph F, herein. With leave of the court, upon good cause shown, additional interrogatories may be propounded.

B. The interrogatories shall be served upon adverse counsel in writing and shall, when possible, be accompanied by the computer disk producing them. The interrogatories are not to be filed with the court, except as provided by paragraph D herein. The interrogating party shall show on the interrogatories the "Certificate of Mailing" and shall file with the court at the time they are mailed a "Certificate of Mailing" of the interrogatories, which shall include the following:

1. the party to whom mailed;

2. the date of mailing;

3. designation of pleading as first interrogatories, second interrogatories, etc; and

4. the signature of attorney or party mailing the interrogatories.

C. The interrogated party shall reproduce the interrogatory before each answer, using the same interrogatory number as in the interrogatories propounded by the opponent, or respond in the space provided on the interrogatories from the interrogating party.

D. If a motion placing the interrogatory in issue is filed, the movant shall contemporaneously file each interrogatory and answer that is the subject of the motion.

E. Where a party files objections to any interrogatories, the interrogatory objected to shall be set out in full before the stated objection.

F. Any party propounding interrogatories in medical negligence, auto accident, premises liability and products liability cases shall use pattern interrogatories approved by the court. No objection to the pattern interrogatories will be entertained by the court, unless the objecting party simultaneously requests leave of court to so object, because of some unusual and/or exceptional reason. After receiving answers to the pattern interrogatories, any party that requires further information may propound up to five additional interrogatories without leave of court. If further information is required after these interrogatories have been answered, additional interrogatories may be propounded only after the party desiring additional information obtains leave of court. Any interrogatories that are propounded in addition to the pattern interrogatories may be objected to as appropriate.

G. Copies of court approved pattern interrogatories are included in the appendix to these local court rules.