§ 3233.Interrogatories to Parties

Section 3233 caps written interrogatories, Oklahoma's version of FRCP 33, at thirty per party -- a slightly higher default than the federal rule's twenty-five -- with interrogatories about the names and locations of witnesses or the existence and custody of documents each counted as one interrogatory, and subdivisions of a single numbered interrogatory each counted separately. Going beyond thirty requires either a written stipulation reached after good-faith consultation with opposing counsel, or, failing that, a motion showing the good-faith attempt, good cause for the additional interrogatories, and their proposed text. Each answer must restate the interrogatory before answering it, and answers are due thirty days after service, though that clock doesn't start until an answer to the petition is filed unless the court or the parties agree otherwise. All grounds for objection must be stated with specificity, and an unstated ground is waived absent good cause shown.

Interrogatories may reach anything discoverable under Section 3226(B), and an interrogatory isn't objectionable merely because it calls for an opinion or a contention about fact or the application of law to fact -- though the court may defer the answer until later discovery, a pretrial conference, or another point. Where the answer can be derived from business records, including electronically stored information, and the burden of deriving it would fall about equally on either side, the responding party may instead specify the records in enough detail for the requesting party to locate and identify them and provide a reasonable opportunity to examine and copy them.