*1 By letter-motion dated September 10, 2020, Defendants in this employment discrimination and breach of contract action seek an order compelling Plaintiff to remedy alleged deficiencies in her interrogatory responses to Defendants’ first set of interrogatories. Dkt. No. 82. Plaintiff has responded by letter dated September 17, 2020 (Dkt. No. 85) that Defendants’ interrogatories violate Rule 33 of the Federal Rules of Civil Procedure because there are more than 25 interrogatories, including discrete subparts. In addition, Plaintiff argues that the interrogatories go beyond permissible boundaries placed by this Court's Local Rule 33.3. She contends that a deposition is a more practical method of obtaining the information sought in the interrogatories.

As a threshold matter, the Court rejects Plaintiff's argument that there are more than 25 interrogatories presented. There are only 8 interrogatories, and each one deals with a discrete subject: interrogatory No. 1 (each position Plaintiff held at Zip Aviation (“Zip”) and Manhattan Helicopter Services (“MH”)); No. 2 (Plaintiff's educational background); No. 3 (Plaintiff's background and qualifications in the aviation industry prior to 2007); No. 4 (every lawsuit Plaintiff has filed); No. 5 (every physical injury Plaintiff alleges that defendant Shoshani caused); No. 6 (every medical condition with which Plaintiff has been diagnosed during the relevant time period); No. 7 (every mental health or psychiatric condition with which Plaintiff has been diagnosed during the relevant time period); and No. 8 (Plaintiff's immigration status from 2007 to present). Only one of the 8 interrogatories has explicit subparts (interrogatory number 1) and to the extent some or all of the others can be construed to have subparts, they are all “logically or factually subsumed” and “necessarily related to the primary question.” Rouvier v. DuPuy Orthopaedics, Inc., No. 18-CV-4814 (LJL) (SDA), 2020 WL 1080775, at *2 (S.D.N.Y. Mar. 7, 2020).

Defendants argue that this case is “far past the commencement of discovery” and therefore Plaintiff's invocation of Local Rule 33.3(a) is inapposite. I disagree. As was established at the August 26 pretrial conference, the parties were barely out of the starting gate discovery-wise at that time, and accordingly were seeking a lengthy extension of the discovery period. Local Rule 33.3(a) contemplates the use of interrogatories at the commencement of discovery (“commencement interrogatories”) only to obtain certain discrete information (i.e., names of witnesses, damages computation, location and custodian of relevant documents etc.), and the interrogatories in question run afoul of those limitations. But even if the Court accepts Defendants’ argument that the parties are actually further along in discovery, Local Rule 33.3(b) provides that “during discovery, interrogatories other than those seeking information” from the commencement interrogatories (“during discovery interrogatories”) may only be utilized “if they are a more practical method of obtaining the information sought that a request for production or a deposition,” or if the Court orders their usage.[1]

*2 It is readily apparent that Defendants’ interrogatories all exceed the limitations of Local Rule 33.3(a), and they do not suggest otherwise. The real issue is whether, as during discovery interrogatories, they are a more practical method of obtaining the information sought than a deposition or a request for documents. The answers depend on the interrogatory, so the Court will review each interrogatory seriatim:

Finally, the Court notes that “[d]iscovery under the Federal Rules is intended to reveal relevant documents and testimony, but this process is supposed to occur with a minimum of judicial intervention.” Zhao v. U.S. Dep't of Homeland Sec., No. 06-CV-106S (HBS), 2010 WL 4642929, at *3 (W.D.N.Y. Nov. 17, 2010) (citation omitted). While the parties in this case slumbered for many months, they have now woken up and since the pretrial conference in late August have already brought two discovery disputes for the Court to resolve.[5] The Court strongly encourages the parties to work together to resolve their disputes, rather than seek judicial intervention each time they disagree about something.

The Clerk is directed to close docket number 82 and mark it as granted in part and denied in part.

*4 SO ORDERED.