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Rule 33.Interrogatories to Parties

Current through July 1, 2026 · Last verified July 13, 2026

In one sentenceRule 33 lets any party serve written interrogatories on another party — to be answered under oath within at least thirty days — while banning vague general objections, requiring reasonable particularity, and letting a responding party point to business records instead of drafting a written answer.

Full Text of Rule 33

Text sizeJump to: (A) (B) (C) (D) (E)

(A) Availability--Procedures for use. Any party may serve upon any other party written interrogatories to be answered by the party served or, if the party served is an organization including a governmental organization, or a partnership, by any officer or agent, who shall furnish such information as is available to the party. Interrogatories may, without leave of court, be served upon the plaintiff after com- mencement of the action and upon any other party with or after service of the summons and complaint upon that party.
(B) Format of interrogatory and response. A party who serves written interrogatories under this rule must provide, after each inter- rogatory, a reasonable amount of space for a response or an objection. Answers or objec- tions to interrogatories must include the interrogatory which is being answered or to which an objection is made. The interrogatory which is being answered or objected to must be placed immediately preceding the answer or objection. Each interrogatory must be answered separately and fully in writing under oath, unless it is objected to, in which event the reasons for objections must be stated in lieu of an answer. The answers are to be signed by the person making them, and the objections signed by the attorney making them. General objections must not be made and will have no effect. A gen- eral objection is an objection that is not directed to a specific interrogatory, does not spe- cifically state the grounds on which it was based, or applies globally.
(C) Time for service, response, and sanctions. The party upon whom the interrogatories have been served must serve a copy of the answers and objections within a period designated by the party submitting the inter- rogatories, not less than thirty days after the service thereof or within such shorter or longer time as the court may allow. The party submitting the interrogatories may move for an order under Rule 37(A) with respect to any objection to or other failure to answer an interrogatory. The party upon whom the interrogatories have been served may object to the failure to fol- low the Format requirements in subdivision (B) by returning the interrogatories to the party who caused them to be served. If this objection is to be made, the interrogatories must be returned to the party who caused them to be served not later than the seventh day after they were received. If the interrogatories are not returned in that time, then this objection is waived.
(D) Scope--Use at trial. Interrogatories may relate to any matters which can be inquired into under Rule 26(B) and must be stated with reasonable particularity, and the answers may be used to the extent per- mitted by the rules of evidence. An interrogatory otherwise proper is not objectionable merely because an answer to the interrogatory involves an opinion, contention, or legal conclusion, but the court may order that such an interrogatory be answered at a later time, or after designated discovery has been completed, or at a pre-trial conference.
(E) Option to produce business records. Where the answer to an interrogatory may be derived or ascertained from the business records of the party upon whom the interrogatory has been served or from an examination, audit or inspection of such business records, including a compilation, abstract or summary thereof, and the burden of deriving or ascertaining the answer is substantially the same for the party serving the interrogatory as for the party served, it is a sufficient answer to such interrogatory to specify the records from which the answer may be derived or ascertained and to afford to the party serving the interrogatory reasonable opportunity to examine, audit or inspect such records and to make copies, compilations, abstracts or summaries. A spe- cification shall be in sufficient detail to permit the interrogating party to locate and to identify, as readily as can the party served, the records from which the answer may be ascertained.

Amendment History

This rule’s current text took effect January 1, 2026. For the full history of earlier amendments and adoption orders, see the Indiana Office of Court Services.

Plain-English Summary

Rule 33 is Indiana’s written-interrogatory rule: one party sends written questions to another, and that party has to answer them in writing, under oath. Section A sets who can serve interrogatories on whom and when. Any party can serve them on any other party without asking the court first — on a plaintiff, once the case has started, and on any other party as soon as that party is served with the summons and complaint. If the party receiving the interrogatories is an organization, including a government entity, or a partnership, an officer or agent answers on its behalf, drawing on whatever information the organization has available, not just personal knowledge.

Section B controls the format and, as of a 2026 amendment, bars a common shortcut: the vague, catch-all objection. The party sending interrogatories has to leave room after each one for an answer or objection, and the interrogatory itself has to sit right above whichever response follows it, so the two stay paired rather than scattered across separate documents. Each interrogatory gets answered separately and fully, in writing, under oath — unless it draws an objection, in which case the reasons have to be spelled out instead of an answer. The person answering signs the answers; the attorney raising an objection signs that. A “general objection” — one that does not target a specific interrogatory, does not spell out its actual grounds, or gets applied across the board — is not allowed and carries no legal weight, which means a party cannot rely on boilerplate language to avoid answering.

Section C sets the response clock and a narrower one for format complaints. The responding party must serve answers and objections within whatever period the interrogatories specify, as long as that period is not shorter than thirty days from service, unless the court sets a different deadline. If the interrogatories fall short of the format rules in section B, the responding party can object by returning them to the sender — but only within seven days of receiving them; miss that window, and the format objection is gone. Whenever a dispute remains over an objection or an unanswered interrogatory, the party who sent the interrogatories can ask the court to step in under Rule 37(A).

Section D marks the outer edges of what interrogatories can reach and how they have to be written. They can probe anything discoverable under Rule 26(B), and — also as of the 2026 amendment — must be stated with reasonable particularity rather than left open-ended or vague. An interrogatory that calls for an opinion, a contention, or a legal conclusion is not automatically objectionable just because of that; the court can instead push the answer to a later point, until designated discovery wraps up, or until a pretrial conference.

Section E gives a responding party an alternative to writing out an answer by hand: if the answer sits in the responding party’s business records — including something a records review, audit, or inspection would reveal — and pulling the answer from those records would take about the same effort for either side, the responding party can point to the specific records instead of answering directly. That option comes with strings attached: the response has to describe the records precisely enough that the party asking the questions can locate the answer as easily as the party who holds the records could, and the responding party has to give real access to examine, copy, and compile from them.

Two things set Indiana’s interrogatory practice apart from the federal rule. Trial Rule 33 does not cap the number of interrogatories a party may serve, while the federal rule defaults to twenty-five, subparts included, absent a stipulation or court order. And the ban on general objections, along with the reasonable-particularity requirement in section D, are recent additions, effective January 1, 2026 — a sign Indiana has moved to cut down on boilerplate discovery responses.

Frequently Asked Questions

How long do I have to answer interrogatories in Indiana?

At least thirty days from when you were served, though the party who sent the interrogatories can allow more time, and the court can shorten or extend that period. The thirty-day floor cannot be shortened by the sender alone.

Can I object to interrogatories with a boilerplate statement like “overbroad and unduly burdensome” without saying more?

No. Rule 33(B) prohibits general objections — ones that do not target a specific interrogatory, do not state their actual grounds, or get applied across the board — and says they carry no effect. Every objection has to point to a particular interrogatory and explain, in that spot, exactly why it is improper.

Who has to sign my interrogatory answers?

The person who answers signs the answers — that is the responding party, or for an organization, the officer or agent who supplied the information. Any objections get signed separately by the attorney raising them.

Can I answer an interrogatory by just handing over a pile of business records?

Only under the conditions in Rule 33(E): the answer has to be derivable from those records, and pulling it out has to take about the same effort for both sides. Even then, you must describe the records specifically enough that the other party can find the answer as easily as you could, and give them a real opportunity to examine and copy them.

What happens if the interrogatories I received do not follow the spacing and pairing format Rule 33 requires?

You can object to that formatting problem by returning the interrogatories to the party who served them, but only within seven days of receiving them. Wait longer than that, and the format objection is waived, though your other rights to object on the merits are not affected by that particular deadline.

Can I refuse to answer an interrogatory just because it asks for my legal position on an issue?

No, not on that ground alone. Rule 33(D) says an interrogatory is not objectionable merely because answering it calls for an opinion, a contention, or a legal conclusion. A court can, however, delay when that kind of answer is due — pushing it to a later stage of discovery or a pretrial conference.

Is there a limit on how many interrogatories one party can send another in Indiana?

Trial Rule 33 does not set one. That is a departure from the federal rule, which caps interrogatories at twenty-five, including subparts, unless the parties stipulate to more or the court allows it.

Source & verification. The rule text is reproduced verbatim from the official Indiana Rules of Trial Procedure (T.R. 33). Prescribed by the Supreme Court of Indiana, under its inherent constitutional rulemaking power (reaffirmed by Ind. Code 34-8-1-1 and 34-8-2-1); originally enacted by the Indiana General Assembly in 1969. The plain-English summary is original and written by us. Last verified July 13, 2026. · Official source
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