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Unless otherwise specified in the preliminary conference order, only 25 interrogatories may be served in any action, including consolidated actions.
Interrogatories can only be sent to the opposing party they cannot be sent to experts or other witnesses. The disadvantage of interrogatories is that the answers are typically prepared by the attorney rather than by the client.
A subpoena is typically requested by an attorney on behalf of the court and issued by a court clerk, notary public or justice of the peace. A subpoena may be served on an individual either through personal delivery, email, certified mail or even by reading it out aloud.
How to Persuade a Judge Your arguments must make logical sense. Know your audience. Know your case. Know your adversarys case. Never overstate your case. If possible lead with the strongest argument. Select the most easily defensible position that favors your case. Dont try to defend the indefensible.
Parties may obtain discovery by one or more of the following methods: depositions by oral examination or written questions; written interrogatories; production of documents or things or permission to enter upon land or other property; for inspection and other purposes; physical (including blood) and mental examinations
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Rule 5 prescribes the procedure at the defendants initial appearance. In most misdemeanor cases, the initial appearance will also be the time of arraignment and disposition. Rule 5.02 requires the appointment of a qualified interpreter for a defendant disabled in communication.
No party may serve more than a total of 50 interrogatories upon any other party unless permitted to do so by the court upon motion, notice and a showing of good cause.
Misjoinder and Nonjoinder of Parties. Misjoinder of parties is not ground for dismissal of an action. Parties may be dropped or added by order of the court on motion of any party or upon the courts own initiative at any stage of the action and on such terms as are just.
In cases where a party has not propounded pattern interrogatories pursuant to LCR 33, a party may serve no more than 40 interrogatories, including all discrete subparts.
If production or inspection is made at a time or place, in a manner, or to an extent and scope, different from that commanded in the subpoena, the party issuing the subpoena must give notice to all parties to the action at least seven days in advance of the rescheduled production.

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