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The answering party shall serve a copy of the answers, and objections if any, within thirty days after the service of the interrogatories.
The delayed discovery rule in California says is the legal maxim that the statute of limitations on bringing a claim does not start running until a claimant discovers the injury or loss that forms the basis of the claim or lawsuit.
Your answers to the interrogatories should usually be short, clear, and direct and should answer only the question that is being asked. This is not the time to set out your entire case or defense to the other side. Take the time to make sure your answers are correct and truthful.
The discovery rule is triggered when a person exhibiting reasonable diligence would have discovered the injury and that it was caused by another.
However, in the absence of cause shown, the Pennsylvania rules of civil procedure do not permit an expert to be deposed.
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Under Rule 4003.5(a)(4) of the Pennsylvania Rules of Civil Procedure, draft expert reports and attorney-expert communications are explicitly protected from discovery \u201cexcept in circumstances that would warrant the disclosure of privileged communications under Pennsylvania law.\u201d This is a recent development in ...
Among other things, they can be used as an attempt to tie up the opposing party rather than to obtain discovery. The legitimate purpose of contention interrogatories is to narrow the issues for trial, not to force the opposing side to marshal all its evidence on paper.
Without leave of Court or written consent, any party may serve upon any other party written Interrogatories not exceeding 50 in number, including all discreet subparts. Leave to serve additional Interrogatories may be granted by Order of Court upon cause shown and consistent with the provisions of Pa. R.C.P.
Interrogatories are to be raised at a pre-trial stage and must have a close connection with the matter in question, whereas cross examinations have a wider scope of questions that can be asked.
In New York practice, written communications between a testifying expert and an attorney are potentially discoverable if the expert is subpoenaed.

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