Credit: vladwel/Adobe stock 
The Commercial Division designed its rules to streamline discovery and to seek to reduce costs making litigating commercial cases more efficient. To that end, the Commercial Division's rule governing interrogatories, Rule 11-a, aims to meet these goals by limiting the use of this discovery tool much more than other courts in New York state.
Numerical Limitations
Rule 11-a limits interrogatories to 25, including subparts, unless another limit is specified in the preliminary conference order. The court in AXA Mediterranean Holding v. ING Inc. Intern. B.V., (2013 WL 6212568, at *5 (N.Y. Sup. Ct. Sep. 04, 2013) (J. Bradley)), was the first decision to examine and define "subparts." Looking to the Federal Rules of Civil Procedure and federal court decisions around the country, the court held "if the subparts cannot be fairly and reasonably characterized as closely related to the first part of the interrogatory, they are therefore discrete and separate." Each part of an interrogatory that "can be answered fully and completely," then, qualifies as its own subpart.
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