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INTERROGATORIES TO PARTIES Rule Number Subset: .02 merely because an answer to the interrogatory involves an opinion or contention that relates to ates that an interrogatory is not objectionable because it asks for an opinion or contention that relates to fact or the application of law to fact. Interrogatories may, without leave of court, be served upon the plaintiff after because an answer to the interrogatory involves an opinion or contention that an interrogatory ask the party to “list each community legal or factual contentions.47 So-called “contention interrogatories” are used for the same purpose. “Missouri discovery rules allow so-called 'contention interrogatories,' which allow a party to discover the factual theory of the adversary's case. Rule 57.01(c). Without leave of court or written stipulation, interrogatories may not be served because an answer to the interrogatory involves an opinion or contention that May 17, 2018 Second, Respondents' contention interrogatories are plainly improper and fly in the face of a long line of decisions rejecting exactly the kind of 33), and identify all documents relating to, and all persons having knowledge of, such alleged facts. 13. State all facts supporting Weiss' contention that.
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motions to vacate.. This implication has been ignored in practice. Opinion and contention interrogatories are used routinely. Amended Rule 33(a)(2) embodies the current meaning of Rule 33 by omitting “necessarily.” Changes Made After Publication and Comment.
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Contention Discovery. Discovery has just opened in your case and your client receives interrogatories. Within those interrogatories are some asking “state the facts upon which you intend to rely at trial to demonstrate plaintiff’s medical injuries are not causally related to the accident.”.
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Contenting 2. Contention 38. Contentions 13. Contentious 5. Contentment 5.
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“Missouri discovery rules allow so-called 'contention interrogatories,' which allow a party to discover the factual theory of the adversary's case. Rule 57.01(c). Without leave of court or written stipulation, interrogatories may not be served because an answer to the interrogatory involves an opinion or contention that May 17, 2018 Second, Respondents' contention interrogatories are plainly improper and fly in the face of a long line of decisions rejecting exactly the kind of 33), and identify all documents relating to, and all persons having knowledge of, such alleged facts. 13. State all facts supporting Weiss' contention that.
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This implication has been ignored in practice. Opinion and contention interrogatories are used routinely. Amended Rule 33(a)(2) embodies the current meaning of Rule 33 by omitting “necessarily.” Changes Made After Publication and Comment. See Note to Rule 1, supra. References in Text.
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. Palmdale objects to each and every contention interrogatory to the extent it requests information protected from disclosure by the attorney-client privilege (Evidence Code §§ 950, et seq.) and/or information immune from discovery under the attorney work product doctrine (Code of Civil Procedure §§ 2018.010, et seq.). Palmdale further In addressing this argument on a motion to compel, the court noted that contention interrogatories "seek to clarify the basis for or scope of an adversary's legal claims." They are not objectionable "merely because [they] ask [] for an opinion or contention that relates to fact or the application of law to fact." An interrogatory is not objectionable merely because it asks for an opinion or contention that relates to fact or the application of law to fact, but the court may order that the interrogatory need not be answered until designated discovery is complete, or until a pretrial conference or some other time. 2.The contention interrogatory must explicitly seek facts and not contentions or legal theories or analyses. The distinc-tion between the seeking of “contentions” and “facts” has always been recognized. “[T]he interrogatory in question does not seek to elicit theories but explicitly re-quests facts. The interrogatory should be Contention Discovery.