Group V: Depositions and Discovery · Not amended since adoption on record · Last verified July 13, 2026
In one sentenceRule 33 lets any party serve written interrogatories, commonly called ROGs, on another party, sets response deadlines and a set of standard interrogatories every case may use, and caps general interrogatories at fifty questions unless the amount in controversy, the relief sought, or the court's leave allows more.
(a)Availability; Procedures for Use. Except as limited by paragraph (b)(9), any party may serve upon any other party written interrogatories to be answered by the party served or, if the party served is a public or private corporation or a partnership or association or governmental agency, 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 commencement of the action and upon any other party with or after service of the summons and complaint upon that party.
Each interrogatory shall be answered separately and fully in writing under oath, unless it is objected to, in which event the reasons for objection shall 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. The party upon whom the interrogatories have been served shall serve a copy of the answers, and objections if any, within 30 days after the service of the interrogatories, except that a defendant may serve answers or objections within 45 days after service of the summons and complaint upon that defendant. The court may allow a shorter or longer time. 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.
(b)Standard Interrogatories. In all cases the following standard interrogatories may be served by one party upon another unless otherwise ordered by the court for good cause shown. The interrogatories shall be deemed to continue from the time of service, until the time of trial of the action so that information sought, which comes to the knowledge of a party, or his representative or attorney, after original answers to interrogatories have been submitted, shall be promptly transmitted to the other party.
(1)Give the names and addresses of persons known to the parties or counsel to be witnesses concerning the facts of the case and indicate whether or not written or recorded statements have been taken from the witnesses and indicate who has possession of such statements.
(2)Set forth a list of photographs, plats, sketches or other prepared documents in possession of the party that relate to the claim or defense in the case.
(3)In cases involving personal injury set forth the names and addresses of all physicians who have treated the party and all hospitals to which the party has been committed in connection with said injuries and also set forth a statement of all medical costs involved.
(4)Set forth the names and addresses of all insurance companies which have liability insurance coverage relating to the claim and set forth the number or numbers of the policies involved and the amount or amounts of liability coverage provided in each policy.
(5)Set forth an itemized statement of all damages, exclusive of pain and suffering, claimed to have been sustained by the party.
(6)List the names and addresses of any expert witnesses whom the party proposes to use as a witness at the trial of the case.
(7)For each person known to the parties or counsel to be a witness concerning the facts of the case, set forth either a summary sufficient to inform the other party of the important facts known to or observed by such witness, or provide a copy of any written or recorded statements taken from such witnesses.
(8)[Defendants only.] If the defendant is improperly identified, give the proper identification and state whether counsel will accept service of an amended summons and pleading reflecting the correct information.
(9)Limitations. In addition to the standard interrogatories authorized by this paragraph, the court may order additional interrogatories for good cause shown in any case. In all actions in which the amount in controversy is not less than $ 25,000, and in all actions for declaratory or injunctive relief, or actions before the family court, a party may serve additional interrogatories including more than one set of interrogatories upon any other party; but the total number of general interrogatories to any one party shall not exceed fifty questions including subparts, except by leave of court upon good cause shown.
(c)Option to Produce Business Records. Where the answer to an interrogatory may be derived or ascertained from the business records, including electronically stored information, 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 specification 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.
(d)Scope; Use at Trial. Interrogatories may relate to any matters which can be inquired into under Rule 26(b), and the answers may be used to the extent permitted by the rules of evidence. 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 pre-trial hearing or other later time.
Last amended by Order dated May 1, 2019.
Notes
Note: This Rule 33(a) is the language of current Federal Rule except the first line. This language permits interrogatories to any party, not just an adverse party, and increases the time within which a party may object or respond to 30 days.
Note: Rule 33(b)(5) amends present Circuit Court Rule 90 to require an "itemized" statement of all special damages exclusive of pain and suffering. 33(b)(8) is amended to make clear that in certain cases additional interrogatories are permitted beyond the standard interrogatories. Paragraphs 33(b)(1) through (4) and (6) are verbatim the standard interrogatories permitted by present Circuit Court Rule 90(e)(A) through (D) and (F). Paragraph (b)(7) is new and provides for a summary of the facts known to the witnesses in the case. The rule requires a detailed summary so as to avoid the problem encountered with the interrogatories directed to experts in Federal Rule 26(b)(4)(A)(i) which often results in a short, vague summary of expected testimony. On the other hand, it is limited to important facts known or observed by the witness so that the summary is restricted to the actual knowledge of the witness. Paragraph (b)(8) is added to provide for additional special interrogatories to parties in complex cases. The $ 10,000 limitation follows the approach set by present Circuit Court Rule 87J. The limit of fifty such interrogatories follows present local rules of the Federal courts.
Note to 1985 Amendment: The changes to Rule 33(b)(8) raise the amount in controversy necessary to authorize general interrogatories as a matter of course from $ 10,000 to $ 25,000. The rule is clarified to permit up to fifty general interrogatories in addition to the seven standard interrogatories.
Note to 1988 Amendment: Rule 33(b)(8) is amended to make clear that the court has the discretion to permit additional interrogatories in any case for good cause shown.
Note to 2008 Amendment: This amendment added section (b)(8) relating to defendants.
Note to 2019 Amendment: The amendment to paragraph (b)(9) permits parties in actions before the family court to serve additional interrogatories when engaging in discovery under Rule 25 of the South Carolina Family Court Rules.
Note: This Rule 33(c) is the Federal Rule and permits the party responding to discovery interrogatories to supply the documents from which the information can be obtained when the burden of extracting the information is the same for either party. It places on the requesting party the burden of obtaining the information if he specially needs it.
Note to 2011 Amendment: The amendments to Rules 16, 26, 33, 34, 37 and 45 of the South Carolina Rules of Civil Procedure concerning electronic discovery are substantially similar to the corresponding provisions in the Federal Rules of Civil Procedure. The rules concerning electronic discovery are intended to provide a practical, efficient and cost-effective method to assure reasonable discovery. Pursuit of electronic discovery must relate to the claims and defenses asserted in the pleadings and should serve as a means for facilitating a just and cost-effective resolution of disputes.
Plain-English Summary
Interrogatories are written questions one party sends another, and Rule 33 is the rule that makes them work. Any party can serve them on any other party, and if the party served is a corporation, partnership, association, or government agency, an officer or agent answers using whatever information is available to the organization. Each interrogatory gets a separate, sworn answer, or an objection explaining why it will not be answered. A plaintiff can be served as soon as the action starts; a defendant gets forty-five days after being served with the summons and complaint to respond, while everyone else generally has thirty days after the interrogatories themselves are served.
Rule 33(b) lists eight standard interrogatories that any party can send without drafting custom questions: fact witnesses and any statements taken from them, photographs and prepared documents relating to the claim or defense, treating physicians and hospitals along with an itemized statement of medical costs in personal injury cases, liability insurance coverage and policy limits, an itemized statement of damages apart from pain and suffering, expert witnesses, a summary of what each fact witness knows, and, for defendants, correction of an improperly identified party. These standard interrogatories continue automatically — a party who learns something new after answering must pass it along without waiting to be asked again.
Beyond the standard set, a party generally cannot send more than fifty interrogatories, including subparts, to any one party without the court's permission for good cause. That fifty-question ceiling loosens in cases where the amount in controversy is at least $25,000, in actions seeking declaratory or injunctive relief, and in family court matters, where a party may serve additional interrogatories as a matter of course. Rule 33(c) offers responding parties an alternative to writing out answers: where the answer can be derived from business records equally accessible to both sides, the responding party can point to the records instead, as long as it identifies them specifically enough for the requesting party to find what it needs.
Frequently Asked Questions
What are ROGs in South Carolina litigation?
ROGs is shorthand for interrogatories — written questions served under Rule 33 that the receiving party must answer separately, in writing, and under oath, or object to with stated reasons.
How long does a defendant have to answer interrogatories?
Forty-five days after being served with the summons and complaint. Other parties generally have thirty days from when the interrogatories themselves are served, unless the court sets a different time.
Is there a limit on how many interrogatories a party can send?
Yes, generally fifty questions, including subparts, to any one party without the court's permission. That ceiling does not apply to the eight standard interrogatories listed in Rule 33(b), and it can be raised for good cause or in cases meeting the $25,000 amount-in-controversy threshold, declaratory or injunctive relief cases, and family court matters.
What are the standard interrogatories every South Carolina case can use?
They cover fact witnesses and their statements, photographs and prepared documents, treating physicians and medical costs in injury cases, liability insurance coverage, an itemized damages statement, expert witnesses, witness-knowledge summaries, and, for defendants, correcting a misidentified party.
Can a party answer an interrogatory by pointing to business records instead of writing out an answer?
Yes, under Rule 33(c), when the answer can be derived from records equally accessible to both sides. The responding party must identify the records specifically enough for the other side to locate the answer itself.
Do interrogatory answers have to be sworn?
Yes. Rule 33(a) requires each answer to be signed by the person making it, under oath, while any objection is signed by the attorney raising it.
Source & verification. Rule text, official Notes, and amendment
history are reproduced verbatim from the South Carolina Rules of Civil Procedure,
adopted by the Supreme Court of South Carolina. Last verified July 13, 2026. ·
Official source
Also known as:ROGsinterrogatories South Carolinastandard interrogatories SCwritten interrogatories to partiesanswering interrogatories South Carolina deadline