1)if i made 11 demands for production and 9 of them got objected does it mean i can ask 33 Interrogatories now?
2)If I served demands for production first and titled it REQUEST FOR IDENTIFICATION AND PRODUCTION OF DOCUMENTS AND TANGIBLE THINGS, SET NO. ONE.
do i title Interrogatories as DEFENDANT’S INTERROGATORIES DIRECTED TO PLAINTIFF, SET NO. ONE or SET NO. TWO?
3) can i do traditional discovery and serve Statement of Witnesses and Evidence (Form DISC-015)?