Defendant served a prolix set of interrogatories (over 400 queries in 102 paragraphs) in response to a lengthy (37-page, 118-paragraph) complaint. Although plaintiff objected to the extensiveness of the interrogatories, it never sought modification. It served responses which defendant considered, in the main, to be evasive, incomplete or unresponsive. After unsuccessful informal attempts to get better responses, defendant moved to compel additional answers to the interrogatories...
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