RULE 33                                                
                 INTERROGATORIES TO PARTIES                                      
                                                                                 
    (a) Availability; Procedures for Use. 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 the summons and       
a copy of the complaint are served upon the defendant, or the complaint is       
filed, whichever shall first occur, and upon any other party with or after       
service of the summons and complaint upon that party.                            
    Interrogatories shall be so arranged that after each separate question       
there shall appear a blank space reasonably calculated to enable the             
answering party to place the written response. In the event the responding       
party either chooses to place the response on a separate page or pages or        
must do so in order to complete the response, the responding party shall         
clearly denote the number of the question to which the response relates,         
including the subpart thereof if applicable. 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 40 days           
after service of the summons and complaint upon that defendant. The parties      
may stipulate or any party may move for an order under rule 37(a) with           
respect to any objection to or other failure to answer an interrogatory.         
    (b) 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 pretrial conference or        
other later time.                                                                
    An interrogatory otherwise proper is not objectionable merely because        
the propounding party may have other access to the requested information or      
has the burden of proof on the subject matter of the interrogatory at            
trial.                                                                           
    (c) Option To Produce Business Records. Where the answer to an               
interrogatory may be derived or ascertained from the business records of         
the party upon whom the interrogatory has been served or from an                 
examination, audit or inspection of such business records, or from a             
compilation, abstract or summary based thereon, 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 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.