A. Electronic Form. Any party may, pursuant to Rule 33 of the Fed. R. Civ. P.,
serve upon any other party interrogatories in Writable Electronic Form (as
hereinafter defined) and require that written answers to such interrogatories also
be provided in electronic form, except that a responding party shall retain the
option to produce business records in the form and manner permitted pursuant to
Fed. R. Civ. P. 33(d). Upon request by any party, interrogatories must be served
upon that party in Writable Electronic Form. Unless the serving party specifically
requests that the written answers be provided in hard-copy form, the responding
party shall provide the written answers to such interrogatories in electronic form.
Any party responding in electronic form to interrogatories may serve such
response in a form that may not be altered.
B. Definition of Writable Electronic Form. "Writable Electronic Form" means
a format that allows the recipient to copy or transfer the text of the document into
the written answer or written response, or permits the written answer or written
response to be typed directly into the document, and thus avoids the need to
retype the text.
C. Hard Copy Form. In the event that the parties elect not to use the electronic
form for interrogatories or written responses thereto, interrogatories shall be
prepared in such a fashion that sufficient space for insertion of the written
responses thereto is provided after each interrogatory or sub-section thereof.
The original and two (2) copies shall be served upon the party to whom such
interrogatories is directed. The responding party shall insert answers on the
original interrogatories served upon him or her and shall retain the original and
be the custodian of it. If there is not sufficient space on the original for insertion
of written responses, the responding party may use and attach supplemental
pages for the written responses. In lieu of the foregoing procedure, the
responding party may retype each interrogatory with the response to such
interrogatory appearing immediately thereafter.