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Unless leave of court is obtained, interrogatories may not be served prior to the meeting of the parties under Rule 26(f).
Interrogatories are a discovery tool that the parties can use to have specific questions about a case answered before trial. Interrogatories are lists of questions sent to the other party that s/he must respond to in writing.
Under revised Rule 56.01(b)(2), a court must limit the frequency or extent of discovery in particular circumstances. In particular, if a court determines that the discovery sought is duplicative, outside the scope of discovery or can be obtained through less burdensome means, the court must limit the discovery.
Unlike interrogatories Requests to Produce are not limited in number. Upon receipt from the opposing party your business lawyer working with you will assess whether any requests are objectionable and what should be produced. These production requests are regularly used in lawsuits.
(a) A defendant may propound interrogatories to a party to the action without leave of court at any time. (b) A plaintiff may propound interrogatories to a party without leave of court at any time that is 10 days after the service of the summons on, or appearance by, that party, whichever occurs first.
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Once the time passes, plaintiff is entitled to serve discovery without any procedural hurdles. However, in a federal court action, a party may not serve discovery until after the meeting of counsel under Federal Rule of Civil Procedure 26. This meeting is typically initiated by plaintiffs counsel.
57.01 | Interrogatories to Parties. (a) Scope. Unless otherwise stipulated, ordered by the court, or approved by local rule pursuant to Rule 56.01(b)(8), any party may serve upon any other party no more than 25 written interrogatories, including all discrete subparts.
If you are the plaintiff, you can begin discovery 10 days after you serve the first papers in the case or anytime after the defendant files a response. If you are the defendant, you may begin discovery as soon as the case is filed.

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