A.    Number. In determining the number of interrogatories under Fed. R. Civ. P. 33, each inquiry seeking a discrete item of information is counted as one interrogatory. For example, a request for the “name, address, and telephone number of a person with knowledge” regarding a subject, counts as three interrogatories.

             B.    Definitions not Allowed. A party may not separately define words used in an interrogatory without leave of the court.