Interrogatories

In determining the number of interrogatories under Fed. R. Civ. P. 33, each inquiry seeking a discrete item of information is one interrogatory. For example, a request for the “name, address, and telephone number of a person” contains 3 interrogatories. A party may not separately define words in an interrogatory. 14 Rule 7037-1.

Cooperation in Discovery The court will only consider a discovery motion if the moving party, in the motion, establishes after personal consultation with opposing parties and sincere attempts to resolve differences, the parties cannot reach an accord. The showing must state the date, time, and place of the communications and the names of all participating persons. Personal consultation means person-to-person conversation, either in person or on the telephone. An exchange of letters, faxes, voice mail messages, or e-mails is personal consultation upon a showing that person-to-person conversation was attempted but thwarted by the opposing party.