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Sunday, November 29, 2020

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Hon. Marco A. Hernández, Chief Judge

Mary L. Moran, Clerk of Court

Local Rules of Civil Procedure

LR 33 - Interrogatories

(See Fed. R. Civ. P. 33)

LR 33-1 Interrogatories - Generally

(a) Not Filed With the Court (See LR 5-9)

Unless directed by the Court, interrogatories, objections, and answers will not be filed with the Court. Instead they will be maintained by counsel and made available to parties upon request. Interrogatories presented for filing without Court approval will be returned to the offering party. To facilitate responding, a courtesy copy of the interrogatories must be e-mailed concurrently pursuant to LR 5-9(b).

(b) Use of Non-Filed Interrogatories

This rule does not preclude the use of interrogatories and answers as exhibits or evidence in support of a motion or at trial.

(c) Definitions

Each interrogatory must state in concise language the information requested. In no case may an interrogatory refer to a definition not contained within the interrogatory or the preamble. Only terms actually used in a set of interrogatories may be defined.

(d) Prohibited Form of Interrogatories

Broad general interrogatories, such as those that ask an opposing party to "state all facts on which a claim or defense is based" or to "apply law to facts," are not permitted.

Practice Tip

The word "contention" has been eliminated to clarify that it is not prohibited per se to inquire what another party is contending, although overly broad general interrogatories are prohibited. See, e.g., Equal Emp’t Opportunity Comm'n v. U.S. Bakery, No. CV 03-64-HA, 2003 U.S. Dist. LEXIS 25529, 2003 WL 23538023, at *6-7 (D. Or. Nov. 20, 1993).

LR 33-2 Answers to Interrogatories

  1. Answers and objections to interrogatories must set forth each question in full before each answer or objection. Each objection must be followed by a statement of reasons.
  2. When an objection is made to part of an interrogatory, the remainder of the interrogatory must be answered at the time the objection is made, or within the period of any extension of time to answer, whichever is later.

LR 33-3 Motions to Compel (See Fed. R. Civ. P. 33(b) and LR 37)

(a) Requirements

Motions to compel must set forth only the pertinent interrogatory question, objection, and legal arguments.

(b) Certification Requirements

The Court will deny any motion to compel that does not contain the certification requirements mandated by LR 7-1(a).

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