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The reason you will need consult nearby rules, which are often at the court's website, and the true reason for you really have to consult your jurisdiction's Rules of Civil Procedure (these are different, but related, things) is straightforward. You don't want create simple mistake that costs you the time advantage. If your jurisdiction does not permit "compound" or multi-part questions in discovery, an individual must deliver your interrogatories and requests in proper form. Helpful site If you don't, their objections in order to well-founded, and you can have lost some times you should really be driving them out you have ever had. So read all of the rules regarding discovery carefully and make sure you get it right in form.