Rule 32 - Discovery
Rule 32.2.2 - Form of Interrogatories: Form and Procedure in Civil and Domestic Actions
1. a. The scope of interrogatories is governed by Rules 56.01(b) and 57.01(b) of the Missouri Rules of Civil Procedure.
b. Interrogatories are properly used, for example, to (1) identify experts expected to testify at trial and the general nature of the subject matter on which such experts are expected to testify; (2) identify persons who have witnessed or who have knowledge about relevant events or the subject matter of claims or defenses asserted in the action; (3) identify the custodian of documents that are relevant to claims or defenses asserted in the action; (4) identify specific documents which are themselves the bases of claims or defenses asserted in the action; (5) identify photographs and other likely trial exhibits; (6) provide counsel for the parties an opportunity to determine facts supporting claims or defenses asserted in the action as provided by law; and (7) for other purposes authorized by Supreme Court Rules 56.01 and 57.01, as more fully discussed in Missouri Sources of Proof, The Missouri Bar, Chapter 10 and Missouri Civil Procedure, The Missouri Bar, Rule 57.
2. Any party propounding interrogatories in civil or domestic relations actions shall leave an appropriate space for the answer to each interrogatory or provide a computer disc for use by opposing counsel in responding to the interrogatories.
3. The original interrogatories shall be served upon adverse counsel. Interrogatories are not to be filed with the Court except as provided by Rule 32.6.
4. The answer to each interrogatory shall be typewritten or printed directly under the corresponding question. In the event an answer is too lengthy to be placed in the space provided, it may be attached as an appendix and clearly identified.
5. The adverse party shall prepare an affidavit to be signed by the appropriate party and attach it as the last page of the interrogatories, mailing a copy to each party.
6. The use of prefatory statements, definitions of terms and other directive language submitted with the interrogatories shall not be binding on the party to whom the interrogatories are propounded and therefor is discouraged. The use of such statements does not alter the duties of the respective parties set forth in Local Rule 32 and Missouri Rule 57.01 as they relate to the manner in which the interrogatories shall be answered, by whom, or in what form.
Adopted 08/11/00
Effective 09/11/00