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Louisiana......how many interrogatories are too many?


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My sister is pro se, fighting a civil case in which the plaintiff is a subprime loan lender.  The plaintiff admits to not owning the loan they have sued her over, and they also admit to not servicing it either.  But just as she was trying to get it dismissed for lack of standing, the plaintiff sent her a packet including discovery requests.  I remember reading in the CCP in Louisiana that a party is only allowed to send up to 35 interrogatories, including subparts, without leave of court.  My question is this--when they say "including subparts", do they mean that each subpart DOES count as an interrogatory, or that no matter how many subparts you have, only the numbered interrogatories count towards this total?  They sent her like 24 or 25 interrogatories, but you cross the 35 line before you get to the 12th numbered one.  I believe that this attorney is trying to take advantage of her being a pro se and not following the CCP even though the attorney had to sign the discovery indicating that it conforms to all the requirements pertaining to rules of evidence and procedure.  Also, if they did go beyond what is allowed, should she still answer the first 35 of them or would it be more appropriate to inform the plaintiff that they have gone against what is allowed?

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