Miss. R. Civ. P. 33

(a) Availability; Procedures for Use. Any party may serve as a matter of right upon

any other party written interrogatories not to exceed thirty in number 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. Each interrogatory shall consist of a single question.

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. Leave of court, to be granted upon a showing of necessity, shall be required

to serve in excess of thirty interrogatories.

(b) Answers and Objections

(1) Each interrogatory shall be answered separately and fully in writing under oath,

unless it is objected to, in which event the objecting party shall state the reasons for the

objection and shall answer to the extent the interrogatory is not objectionable.

(2) The answers are to be signed by the person making them, and the objections

signed by the attorney making them.

(3) The party upon whom the interrogatories have been served shall serve a copy of

the answers, and objections if any, within thirty days after the service of the interrogatories,

except that a defendant may serve answers or objections within forty-five days after service

of the summons and complaint upon that defendant. The court may allow a shorter or longer

time.

(4) All grounds for an objection to an interrogatory shall be stated with specificity.

Any ground not stated in a timely objection is waived unless the party’s failure to object is

excused by the court for good cause shown.

(5) 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.

(c) 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 conference

or other later time.

(d) 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 a sufficient answer to such interrogatory to specify the records from

which the answer may be derived or ascertained in sufficient detail to enable the

interrogating party to locate and identify them as readily as the responding party could 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. The

specification provided shall include sufficient detail to permit the interrogating party to

identify readily the individual documents from which the answer may be ascertained.