Interrogatory and Document Request Response Deadline

01 / PRACTICE NOTES

Thirty days from service, with a different trigger for early document requests.

Rule 33(b)(2) requires the responding party to serve its answers and any objections to interrogatories within 30 days after being served with them. Rule 34(b)(2)(A) gives the party to whom a request for production is directed 30 days after being served to respond in writing, or, when the request was delivered early under Rule 26(d)(2), 30 days after the parties' first Rule 26(f) conference. Both rules add that a shorter or longer time may be stipulated to under Rule 29 or be ordered by the court.

Rule 6(a)(1) supplies the count. Exclude the day of service, count every following calendar day, and include the last day. Requests served by email under written consent on Wednesday, September 2, 2026 have day 30 on Friday, October 2, 2026. Service by mail is complete upon mailing, and Rule 6(d) adds three days after the period would otherwise expire, so the same requests mailed on September 2 are due Monday, October 5, 2026. Choose the qualifying-service option in the calculator to see the second date.

Rule 6(d) covers service by mail under Rule 5(b)(2)(C), by leaving the paper with the clerk under Rule 5(b)(2)(D), and by other means the person consented to in writing under Rule 5(b)(2)(F). Service through the court's electronic-filing system or by other electronic means the person consented to in writing falls under Rule 5(b)(2)(E) and follows the regular count. The certificate of service states the method.

02 / PRACTICE NOTES

The response must be complete, specific and signed on time.

Each interrogatory must be answered separately and fully in writing under oath, to the extent it is not objected to (Rule 33(b)(3)). The grounds for objecting must be stated with specificity, and any ground not stated in a timely objection is waived unless the court, for good cause, excuses the failure (Rule 33(b)(4)). The date therefore governs both the answers and the objections.

A response to a request for production states, for each item or category, either that inspection and related activities will be permitted as requested or the grounds for objecting. An objection must state whether any responsive materials are being withheld on the basis of that objection (Rule 34(b)(2)(C)). The production must then be completed no later than the time for inspection specified in the request (Rule 34(b)(2)(B)). Put the production date in the calendar next to the response date.

Discovery from any source opens after the parties have conferred under Rule 26(f), except in proceedings exempt from initial disclosure or when the rules, a stipulation or a court order authorize earlier discovery (Rule 26(d)(1)). A Rule 34 request delivered early under Rule 26(d)(2) is treated by Rule 34(b)(2)(A) as running from the first Rule 26(f) conference, which is the date to enter in the calculator.

03 / PRACTICE NOTES

Seven entries to make when requests arrive.

A short intake routine produces a response date that survives a handoff between lawyers.

1. Record the service date and the service method from the certificate of service.
2. Check whether the requests were delivered early under Rule 26(d)(2).
3. Enter the date and 30 days in the calculator, selecting the extension only for mail, clerk or other consented non-electronic service.
4. Add the state holidays of the district and any clerk's-office closure.
5. Compare the result with the scheduling order and any Rule 29 stipulation.
6. Calendar the response date and the production date as two tasks.
7. Attach the requests and the certificate of service to the task.

04 / PRACTICE NOTES

Stipulations and orders change the date; record them where the date lives.

A written stipulation under Rule 29 or a court order can shorten or lengthen the 30 days. When counsel agrees to an extension by email, save the email and enter the new date in the task, so the calendar and the correspondence say the same thing. When the court sets a date in a scheduling order, that date controls over the default count.

Disclosure obligations interlock with discovery responses. A party that fails to provide information required by Rule 26(a) or (e) is not allowed to use that information or witness to supply evidence on a motion, at a hearing or at a trial, unless the failure was substantially justified or is harmless (Rule 37(c)(1)). Timely responses and timely supplements keep the evidence available for use.

05 / PRACTICE NOTES

RuleX keeps the discovery response date in the case, next to its source.

Create the case in RuleX, add a task for the discovery responses with the calculated due date, and attach the requests, the certificate of service and any stipulation. The case log records the rule, the trigger date and the holidays you applied, so every lawyer on the matter reads the same calculation and can reopen the source behind it.

Attach the requests and the case documents, then ask RuleX to draft the objections and responses in Word, request by request, with the document references in place. Research, drafting and the calendar date live in one case file with the documents, and the 7-day free trial lets you set up your first matter today.