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Rule 33 of the Federal Rules of Civil Procedure provides for the serving by a party upon any other party of written interrogatories, not exceeding 25 in number including all discrete subparts, provided the interrogatories are served after the parties have met and conferred under Rule 26(f) or by local rule. Rule 33(a). Rule 33(c) further provides that the interrogatories may relate to any matters which can be inquired into under Rule 26(b)(1) and that 'an interrogatory otherwise proper is not necessarily objectionable merely because an answer to the interrogatory involves an opinion or contention that relates to fact or the application of law to fact, but the court may order that such an interrogatory need not be answered until after designated discovery has been completed or until a pretrial conference or other later time.' As it now stands, under Rule 33(c), 'there is no longer any automatic rule that an interrogatory must be disallowed merely because it calls for an opinion or contentions.' WRIGHT, MILLER & MARCUS, Federal Practice and Procedure: Civil § 2167 at 247 (2d ed. 1994).


Interrogatories may relate to any matters which can be inquired into under Rule 26(b), and the answers may ...

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