(PC) O'Connor v. Perez, 2:18-cv-01057

Plaintiff Glenn O’Connor, a pro se state prisoner, alleges Eighth Amendment violations after delays in replacing a broken CPAP mask prescribed for sleep apnea.
He submitted multiple medical request forms seeking a replacement part and later filed an inmate appeal; a nurse ultimately placed a call to obtain a replacement.
Defendants are the health-care staff who reviewed his requests and allegedly failed to act promptly.
Plaintiff moved for leave to serve up to 75 interrogatories (unclear if total or per defendant), arguing he needs extensive medical fact inquiry and cannot take depositions or call witnesses.
Defendants opposed, arguing plaintiff made no particularized showing and the facts are straightforward; note that plaintiff may already serve 25 interrogatories per defendant (100 total for four defendants).
The court denied the motion without prejudice, explaining plaintiff submitted no proposed interrogatories, failed to justify exceeding the limits, and may renew with proposed questions and specific reasons; Rule 26(b)(2) limits apply.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plaintiff may serve more interrogatories than the default limit	Needs up to 75 interrogatories (due to medical complexity and pro se status); depositions/witnesses unavailable	No particularized showing; case is simple; plaintiff can serve 25 per defendant (100 total)	Denied without prejudice; plaintiff may use available 25 per defendant and may renew with proposed interrogatories and justification
Standard required of a pro se plaintiff to obtain additional interrogatories	Pro se status warrants leniency; good cause should suffice	Plaintiff must make a particularized showing for extra discovery	Pro se gets leniency but must still show good cause/particularized need and specify proposed interrogatories

Archer Daniels Midland Co. v. Aon Risk Services, Inc. of Minn., 187 F.R.D. 578 (D. Minn. 1999) (requiring a particularized showing to exceed interrogatory limits)