Local Rule LR5-208. Written interrogatories.

[Related Statewide Rule 1-033 NMRA] A. Limit. No more than fifty (50) interrogatories per party may be served without leave of the court. Each discrete sub-part shall be considered an interrogatory. B. Supplemental interrogatories. Subject to the provisions of Rules 1-026 and 1- 033 NMRA, supplemental interrogatories seeking disclosure of witnesses and exhibits shall be supplemented no less than thirty (30) days before trial. C. Counting interrogatories. The following interrogatories shall be counted as one: (1) the first interrogatory requesting biographical information of the person, corporation, or other entity that is a party to the lawsuit, which may request names, addresses, places of doing business, social security number, age, marriage, children, occupation, and such other permitted biographical data; (2) an interrogatory on expert witnesses, which may request names, addresses, job titles, qualifications, and matters set forth in Rule 1-026(B)(5) NMRA; (3) an interrogatory on lay witnesses, which may request names, addresses, job titles, relationship to any party, subject matter, and a summary of the anticipated testimony; and (4) an interrogatory on exhibits, which may request titles, descriptions of contents, identification of any limited purpose for which the exhibit will be offered, and the names, addresses, and job titles of authenticating witnesses and current custodians. D. Interrogatories that request completion of forms. When an interrogatory requests the completion of a form, every space of the form shall be considered one interrogatory, subject however to the provisions of Paragraph C of this rule. E. Preliminary instructions and preliminary general objections not permitted. Interrogatories shall not include preliminary instructions. Answers to interrogatories shall not include preliminary general objections applicable to all interrogatories.