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Use a Special Interrogatory (sometimes called a Specially Prepared Interrogatory) if you want to write the questions yourself. You use this if you want to ask questions that are specific to your case and are not included on the Form Interrogatory form.
Rule 33. Interrogatories to Parties Interrogatories may, without leave of court, be served upon any party after service of the summons and complaint. 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.
Ask for a court order If the other person does not respond, or their response is still incomplete, you can ask the court to order them to respond. You have 45 days from the service of the most recent responses to ask the court to make an order requiring an answer.
Interrogatories can be quicker, less costly, and less complicated than depositions, but there are downsides. Since the questions are written, the witness may have more time to think and craft answers, rather than providing more candid answers during discovery.
If the opposing side does not respond to your form interrogatories, special interrogatories, or request for production, you may file a motion seeking an order compelling the opposing party to respond.
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Interrogatories allow the parties to ask who, what, when, where and why questions, making them a good method for obtaining new information in a case. There are two types of interrogatories: form interrogatories and special interrogatories.

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