The custom in Tennessee is that interrogatories, requests for production of documents, and requests to admit are sequentially numbered.
That is as it should be.
But when serving a second set of any of these discovery tools, that practice is not used. Instead, 90% of lawyers (maybe more) number the first interrogatory in the second set of discovery with a second “Interrogatory No. 1.”
That means there are two interrogatories marked “No. 1,” one in each set of discovery.
This is foolish, unnecessary, and easily avoided. It is done by those who have never actually had to use that discovery at trial.
When drafting a second set of discovery, I urge you to pick up the sequential numbering for each tool where it was stopped at the end of the earlier set of discovery.
For example, if your first set of discovery had 10 interrogatories and 12 requests for production, make the first interrogatory in your second set of discovery “Interrogatory No. 11” and the first request for production in your second set of discovery “Request No. 13.”
This will avoid confusion at trial and in pretrial trial proceedings.