Okla. Stat. tit. 12, § 12-3233: Interrogatories to parties

A. AVAILABILITY; PROCEDURES FOR USE. Any party may serve upon

any other party written interrogatories 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 that

party.

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 objection and shall

answer to the extent the interrogatory is not objectionable. When

answering each interrogatory, the party shall restate the

interrogatory, then provide the answer. The number of

interrogatories to a party shall not exceed thirty in number.

Interrogatories inquiring as to the names and locations of

witnesses, or the existence, location and custodian of documents or

physical evidence shall be construed as one interrogatory. All

other interrogatories, including subdivisions of one numbered

interrogatory, shall be construed as separate interrogatories. No

further interrogatories will be served unless authorized by the

court. If counsel for a party believes that more than thirty

interrogatories are necessary, counsel shall consult with opposing

counsel promptly and attempt to reach a written stipulation as to a

reasonable number of additional interrogatories. Counsel are

expected to comply with this requirement in good faith. In the

event a written stipulation cannot be agreed upon, the party seeking

to submit such additional interrogatories shall file a motion with

the court (1) showing that counsel have conferred in good faith but

sincere attempts to resolve the issue have been unavailing, (2)

showing reasons establishing good cause for their use, and (3)

setting forth the proposed additional interrogatories. The answers

are to be signed by the person making them, and the objections

signed by the attorney making them. Interrogatories may, without

leave of court, be served upon any party after the filing of a

petition. The party upon whom the interrogatories have been served

shall serve a copy of the answers, and objections if any, within

thirty (30) days after the service of the interrogatories. The 30-

day response period shall not commence until an answer to the

petition is filed. However, upon leave of court or otherwise agreed

to in writing by the parties subject to Section 3229 of this title,

answers to interrogatories may be required prior to the filing of an

answer to the petition. 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. The party

submitting the interrogatories may move for an order under

subsection A of Section 3237 of this title with respect to any

objection to or other failure to answer an interrogatory.

B. SCOPE; USE AT TRIAL. Interrogatories may relate to any

matters which can be inquired into under subsection B of Section

3226 of this title, and the answers may be used to the extent

permitted by the Oklahoma Evidence Code as set forth in Sections

2101 et seq. of this title.

An interrogatory otherwise proper is not necessarily

objectionable because an answer to the interrogatory involves an

opinion or contention that relates to fact or the application of law

to fact. The court may order that such an interrogatory need not be

answered until after designated discovery has been completed or

until a pretrial conference or other later time.

C. OPTION TO PRODUCE BUSINESS RECORDS. Where the answer to an

interrogatory may be derived or ascertained from the business

records, including electronically stored information, of the party

t such an interrogatory need not be

answered until after designated discovery has been completed or

until a pretrial conference or other later time.

C. OPTION TO PRODUCE BUSINESS RECORDS. Where the answer to an

interrogatory may be derived or ascertained from the business

records, including electronically stored information, of the party

upon whom the interrogatory has been served or from an examination,

audit or inspection of such business records, including a

compilation, abstract or summary thereof, 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 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 thereof. A specification shall be in

sufficient detail to permit the party submitting the interrogatory

to locate and to identify, as readily as can the party served, the

records from which the answer may be ascertained.