(a) Interrogatories shall be listed in consecutive order. The party answering interrogatories shall repeat
each question, including subparts, in full immediately prior to each corresponding answer. Upon request,
interrogatories shall be provided in electronic word processing format for ease of answering if technologically
feasible.
b) If the person who verifies the answers to interrogatories does not have personal knowledge of the
information contained in the answers, that person shall, for each answer not verified by personal knowledge,
identify the person or persons from whom the information was obtained or, if the source of the information is
documentary, provide a full description including the location thereof.
(c) Where a claim of privilege is asserted in responding or objecting to any discovery requested in
interrogatories and information is not provided on the basis of such assertion, the party asserting the privilege
shall in the response or objection identify the nature of the privilege (including work product) which is being
claimed and if the privilege is being asserted in connection with a claim or defense governed by state law, set
forth the state privilege rule being invoked. When any privilege is claimed, the party asserting it shall indicate,
as to the information requested, whether (a) any documents exist, or (b) any oral communications took place.
(d) Contention interrogatories shall not be served until 60 days prior to the close of fact discovery
unless otherwise permitted by the Court.
Amended: March 18, 2011; June 21, 2021; April 23, 2024.
