(1) Definition. Interrogatories are written questions served by a party on another party and answered in writing and under oath.

(2) Number. In connection with any petition, unless the parties agree or the court orders otherwise, a party may serve on any other party no more than 40 written interrogatories. A uniform interrogatory and its subparts count as one interrogatory. Any subpart to a non-uniform interrogatory is considered a separate interrogatory.

(3) Scope. An interrogatory may ask about any matter allowed under Rule 51(b). An interrogatory is not improper merely because it asks for an opinion. An interrogatory may ask for a party's contention about facts or the application of law to facts, but the court may, on motion, order that such a contention interrogatory need not be answered until a later time.

(4) Uniform Interrogatories. Rule 97, Form 7, contains uniform interrogatories that a party may use under this rule. A party may use a uniform interrogatory when it is appropriate to the legal or factual issues of the particular action, regardless of how the action or claims are designated. The use of uniform interrogatories is not mandatory. A party propounding a uniform interrogatory may do so by serving a notice that identifies the uniform interrogatory by form and number. A party may limit the scope of a uniform interrogatory--such as by requesting a response only as to particular persons, events, or issues--without converting it into a nonuniform interrogatory.

(5) Service.

(1) Time to Respond. Unless the parties agree or the court orders otherwise, the responding party must serve its answers and any objections within 40 days after being served with the interrogatories. But a respondent may serve its answers and any objections within 60 days after service--or execution of an acceptance of service--of the summons and petition.

(2) Answers Under Oath. Subject to Rule 60(b)(3), an answering party must answer each interrogatory separately and fully in writing under oath. In answering an interrogatory, a party must furnish the information available to it. It must also reproduce the text of an interrogatory immediately above its answer to that interrogatory.

(3) Objections. The grounds for objecting to an interrogatory must be stated with specificity. Any ground not stated in a timely objection is waived unless the court, for good cause, excuses the failure. If a party states an objection, it must still answer the interrogatory to the extent that it is not objectionable.

(4) Signature. The party who answers the interrogatories must sign them under oath. An attorney who objects to any interrogatories must sign the objections.

(5) Service. The answering party must serve the original answers, with any objections, on the propounding party, and must serve a copy on every other party who has appeared in the action. The answering party must not file interrogatory answers with the court.

(1) specifying the records that must be reviewed, in sufficient detail to enable the interrogating party to locate and identify them as readily as the responding party could; and

(2) giving the interrogating party a reasonable opportunity to examine and audit the records and to make copies, compilations, abstracts, or summaries.