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Rule 57.01.Interrogatories to Parties.

Part I · Rule 57: Interrogatories and Depositions · Last amended January 1, 2027 · Last verified July 22, 2026

This rule prints two full, separately-dated versions in the official compilation (a pending or recent amendment straddle); both are shown below.

In one sentenceRule 57.01 lets any party serve up to 25 written interrogatories on any other party, sets the deadlines for objecting and answering, and lets a responding party point to its own business records instead of drafting a narrative answer.

Full Text of Rule 57.01

Text sizeEffective until January 1, 2027 — jump to: (a) (b) (c) (d) (e) (f)

Effective January 1, 2027 — jump to: (a) (b) (c) (d) (e) (f)

Rule 57.01. Interrogatories to Parties. — Effective until January 1, 2027
(a) Scope. Unless otherwise stipulated, ordered by the court, or approved by local rule pursuant to Rule 56.01(b)(8), any party may serve upon any other party no more than 25 written interrogatories, including all discrete subparts. Interrogatories may relate to any matter that can be inquired into under Rule 56.01. 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.
(b) Issuance.
(1) Form. Interrogatories shall be in consecutively numbered paragraphs. The title shall identify the party to whom they are directed and state the number of the set of interrogatories directed to that party.
(2) When Interrogatories May Be Served. Without leave of court, interrogatories may be served on:
(A) A plaintiff after commencement of the action, and
(B) Any other party with or after the party was served with process, entered an appearance, or filed a pleading.
(3) Service. Copies of the interrogatories shall be served on all parties not in default. The party issuing the interrogatories shall also provide each answering party an electronic copy, in a commonly used medium such as a diskette, CD-ROM or as an e-mail attachment, in a format that can be read by most commonly used word processing programs, such as Word for Windows or WordPerfect 5.x or higher. In addition to the information normally in a certificate of service, the certificate of service shall also state:
(A) The name of each party who is to respond to the interrogatories;
(B) The number of the set of interrogatories,
(C) The format of the electronic copy and the medium used to transmit the electronic copy to the responding party.
At the time of service, a certificate of service, but not the interrogatories, shall be filed with the court as provided in Rule 57.01(d).
(c) Response. The interrogatories shall be answered by each party to whom they are directed. If they are directed to a public or private corporation, limited liability company, partnership, association, or governmental agency, they shall be answered by an officer or agent. The party answering the interrogatories shall furnish such information as is available to the party.
(1) When the Response Is Due. Responses shall be served within 30 days after the service of the interrogatories. A defendant, however, shall not be required to respond to interrogatories before the expiration of 45 days after the earlier of:
(A) The date the defendant enters an appearance, or
(B) The date the defendant is served with process.
The court may allow a shorter or longer time.
(2) Form. The title of the response shall identify the responding party and the number of the set of interrogatories. The response to the interrogatories shall quote each interrogatory, including its original paragraph number, and immediately thereunder state the answer or all reasons for not completely answering the interrogatory, including privileges, the work product doctrine, and objections.
(3) Objections and Privileges. If information is withheld because of an objection, then each reason for the objection shall be stated. If a privilege or the work product doctrine is asserted as a reason for withholding information, then without revealing the protected information, the objecting party shall state information that will permit others to assess the applicability of the privilege or work product doctrine.
(4) Option to Produce Business Records. If the answer to an interrogatory may be derived or ascertained from:
(A) The business records of the party upon whom the interrogatory has been served,
(B) An examination, audit, or inspection of such business records, or
(C) A compilation, abstract, or summary based thereon, 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.
(5) Signing. Answers shall be signed under oath by the person making them. Objections shall be signed by the attorney making them or by the self-represented party.
(6) Service. The party to whom the interrogatories were directed shall serve a signed original of the answers and objections, if any, on the party that issued the interrogatories and a copy on all parties not in default. The certificate of service shall state the name of the party who issued the interrogatories and the number of the set of interrogatories.
At the time of service, a certificate of service, but not the response, shall be filed with the court as provided in Rule 57.01(d).
(d) Filing. Interrogatories and answers under this Rule 57.01 shall not be filed with the court except upon court order or contemporaneously with a motion placing the interrogatories in issue. However, both when the interrogatories and answers are served, the party serving them shall file with the court a certificate of service.
The certificate shall show the caption of the case, the name of the party served, the date and manner of service, the designation of the document, e.g., first interrogatories or answers to second interrogatories, and the signature of the serving party or attorney. The answers bearing the original signature of the party answering the interrogatories shall be served on the party submitting the interrogatories, who shall be the custodian thereof until the entire case is finally disposed.
Copies of interrogatory answers may be used in all court proceedings to the same extent the original answers may be used.
(e) Enforcement. The party submitting the interrogatory may move for an order under Rule 61.01(b) with respect to any objection to or other failure to answer an interrogatory.
(f) Use at Trial. Interrogatory answers may be used to the extent permitted by the rules of evidence.
Rule 57.01. Interrogatories to Parties. — Effective January 1, 2027
(a) Scope. Unless otherwise stipulated, ordered by the court, or approved by local rule pursuant to Rule 56.01(b)(8), any party may serve upon any other party no more than 25 written interrogatories, including all discrete subparts. Interrogatories may relate to any matter that can be inquired into under Rule 56.01. 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.
(b) Issuance.
(1) Form. Interrogatories shall be in consecutively numbered paragraphs. The title shall identify the party to whom they are directed and state the number of the set of interrogatories directed to that party.
(2) When Interrogatories May Be Served. Without leave of court, interrogatories may be served on:
(A) A plaintiff after commencement of the action, and
(B) Any other party with or after the party was served with process, entered an appearance, or filed a pleading.
(3) Service. Copies of the interrogatories shall be served on all parties not in default. The party issuing the interrogatories shall also provide each answering party an electronic copy in a format that can be read by most commonly used word processing programs. In addition to the information normally in a certificate of service, the certificate of service shall also state:
(A) The name of each party who is to respond to the interrogatories;
(B) The number of the set of interrogatories,
(C) The format of the electronic copy and the medium used to transmit the electronic copy to the responding party. At the time of service, a certificate of service, but not the interrogatories, shall be filed with the court as provided in Rule 57.01(d).
(c) Response. The interrogatories shall be answered by each party to whom they are directed. If they are directed to a public or private corporation, limited liability company, partnership, association, or governmental agency, they shall be answered by an officer or agent. The party answering the interrogatories shall furnish such information as is available to the party.
(1) When the Response Is Due. Responses shall be served within 30 days after the service of the interrogatories. A defendant, however, shall not be required to respond to interrogatories before the expiration of 45 days after the earlier of:
(A) The date the defendant enters an appearance, or
(B) The date the defendant is served with process.
The court may allow a shorter or longer time.
(2) Form. The title of the response shall identify the responding party and the number of the set of interrogatories. The response to the interrogatories shall quote each interrogatory, including its original paragraph number, and immediately thereunder state the answer or all reasons for not completely answering the interrogatory, including privileges, the work product doctrine, and objections.
(3) Objections and Privileges. If information is withheld because of an objection, then each reason for the objection shall be stated. If a privilege or the work product doctrine is asserted as a reason for withholding information, then without revealing the protected information, the objecting party shall state information that will permit others to assess the applicability of the privilege or work product doctrine.
(4) Option to Produce Business Records. If the answer to an interrogatory may be derived or ascertained from:
(A) The business records of the party upon whom the interrogatory has been served,
(B) An examination, audit, or inspection of such business records, or
(C) A compilation, abstract, or summary based thereon, 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.
(5) Signing. Answers shall be signed under oath by the person making them. Objections shall be signed by the attorney making them or by the self-represented party.
(6) Service. The party to whom the interrogatories were directed shall serve a signed original of the answers and objections, if any, on the party that issued the interrogatories and a copy on all parties not in default. The certificate of service shall state the name of the party who issued the interrogatories and the number of the set of interrogatories.
At the time of service, a certificate of service, but not the response, shall be filed with the court as provided in Rule 57.01(d).
(d) Filing. Interrogatories and answers under this Rule 57.01 shall not be filed with the court except upon court order or contemporaneously with a motion placing the interrogatories in issue. However, both when the interrogatories and answers are served, the party serving them shall file with the court a certificate of service.
The certificate shall show the caption of the case, the name of the party served, the date and manner of service, the designation of the document, e.g., first interrogatories or answers to second interrogatories, and the signature of the serving party or attorney. The answers bearing the original signature of the party answering the interrogatories shall be served on the party submitting the interrogatories, who shall be the custodian thereof until the entire case is finally disposed.
Copies of interrogatory answers may be used in all court proceedings to the same extent the original answers may be used.
(e) Enforcement. The party submitting the interrogatory may move for an order under Rule 61.01(b) with respect to any objection to or other failure to answer an interrogatory.
(f) Use at Trial. Interrogatory answers may be used to the extent permitted by the rules of evidence.

Amendment History

Effective until January 1, 2027

Adopted March 29, 1974, eff. Jan. 1, 1975. Amended June 1, 1993, eff. Jan. 1, 1994; Amended Sept. 26, 1995, eff. July 1, 1996; Amended Apr. 27, 1999, eff. Jan. 1, 2000; Amended June 21, 2005, eff. January 1, 2006. Amended December 22, 2009, effective July 1, 2010; Amended eff. August 28, 2019; Amended eff. September 2, 2021.

Effective January 1, 2027

Adopted March 29, 1974, eff. Jan. 1, 1975. Amended June 1, 1993, eff. Jan. 1, 1994; Amended Sept. 26, 1995, eff. July 1, 1996; Amended Apr. 27, 1999, eff. Jan. 1, 2000; Amended June 21, 2005, eff. January 1, 2006. Amended December 22, 2009, effective July 1, 2010; Amended eff. August 28, 2019; Amended eff. September 2, 2021; Amended June 2, 2026, eff. January 1, 2027.

Plain-English Summary

Rule 57.01 is Missouri’s interrogatory rule — the mechanism for asking another party written questions they must answer under oath. Absent a stipulation, court order, or local rule approving more, a party may serve no more than 25 interrogatories on any other party, counting every discrete subpart toward that total. The questions can reach anything within Rule 56.01’s discovery scope, and an interrogatory is not objectionable merely because answering it calls for an opinion or a contention about how the law applies to the facts, though a court can put off answering that kind until later discovery or a pretrial conference has caught up.

The mechanics are precise. Interrogatories go out in consecutively numbered paragraphs, identifying the responding party and the set number, and can be served on a plaintiff once the action starts or on any other party once that party has been served, entered an appearance, or filed a pleading. Responses are due within 30 days, though a defendant gets a floor of 45 days from the earlier of appearance or service of process. The response has to quote each interrogatory by its original number and then answer it or state every reason — privilege, work product, or other objection — for not answering completely. A party who would otherwise have to comb through its own records to answer can instead point the requesting party to those business records, so long as the burden of digging out the answer is roughly the same either way.

Interrogatories and their answers stay out of the court file except by court order or when a motion puts them at issue; instead, the parties file a certificate of service documenting what went out and when. If a party won’t answer, or answers evasively, the party who sent the interrogatories can move for relief under Rule 61.01(b). Once answered, the responses can be used at trial to the extent the rules of evidence allow.

Frequently Asked Questions

How many interrogatories can I send to another party?

No more than 25, counting every discrete subpart, unless the parties stipulate to more, the court orders otherwise, or a local rule approves a different set of interrogatories under Rule 56.01(b)(8).

When are answers to interrogatories due?

Within 30 days of service. A defendant does not have to respond before 45 days have passed since the earlier of entering an appearance or being served with process, though the court can shorten or lengthen either deadline.

Can I answer an interrogatory by just handing over my business records?

Yes, if the answer can be derived from those records and the burden of digging it out would be about the same for either side. You must specify the records and give the requesting party a real opportunity to examine, copy, or summarize them.

What happens if the other party won’t answer my interrogatories, or leaves an answer incomplete?

An evasive or incomplete answer counts as a failure to answer, and the party who sent the interrogatories can move for an order compelling a response under Rule 61.01(b), which can lead to sanctions including striking pleadings or a default judgment.

Do interrogatories and their answers get filed with the court?

No, not unless the court orders it or a motion places them at issue. The parties instead file a certificate of service showing who was served, when, and with which set of interrogatories.

Can an interrogatory ask for an opinion or a legal contention?

Yes. An interrogatory is not objectionable just because answering it requires an opinion or a conclusion about how the law applies to the facts, though the court can order that this type of question be answered later, once more discovery is done.

Source & verification. Rule text and amendment history are reproduced verbatim from the Missouri State & Federal Court Rules, adopted by the Supreme Court of Missouri. Last verified July 22, 2026. · Official source
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