D. Mass. L.R. 33.1

(a) Form of Response.

(1) Answers and objections in response to interrogatories, served pursuant to Fed. R.

Civ. P. 33 shall be made in the order of the interrogatories propounded.

(2) Each answer, statement, or objection shall be preceded by the interrogatory to

which it responds.

(3) Each objection and the grounds therefor shall be stated separately.

(b) Reference to Records. Whenever a party answers any interrogatory by reference to

records from which the answer may be derived or ascertained, as permitted in Fed. R. Civ.

P. 33(c):

(1) the specification of documents to be produced shall be in sufficient detail to permit

the interrogating party to locate and identify the records and to ascertain the answer

as readily as could the party from whom discovery is sought;

(2) the producing party shall make available any computerized information or

summaries thereof that it either has, or can adduce by a relatively simple procedure,

unless these materials are privileged or otherwise immune from discovery;

(3) the producing party shall provide any relevant compilations, abstracts, or

summaries in its custody or readily obtainable by it, unless these materials are

privileged or otherwise immune from discovery; and

(4) the documents shall be made available for inspection and copying within 14 days

after service of the answers to interrogatories or at a date agreed upon by the parties.

(c) Objections to Interrogatories.

(1) When an objection is made to any interrogatory, or subpart thereof, it shall state

with specificity all grounds upon which the objecting party relies. Any ground not

stated in an objection within the time provided by the Federal Rules of Civil

Procedure, or any extensions thereof, shall be deemed waived.

(2) No part of an interrogatory shall be left unanswered merely because an objection is

interposed to another part of the interrogatory.

(d) Answers to Interrogatories Following Objections. Answers to interrogatories with

respect to which objections were served and which are subsequently required to be

answered shall be served within 14 days after it is determined that they should be answered,

unless the court directs otherwise.

(e) Claims of Privilege. When a claim of privilege is asserted in objection to any interrogatory,

or any subpart thereof, and an answer is not provided on the basis of that assertion, the

attorney asserting the privilege shall identify in the objection the nature of the privilege that

is being claimed. If the privilege is being asserted in connection with a claim or defense

governed by state law, the attorney asserting the privilege shall indicate the particular

privilege rule that is being invoked.