Maryland Circuit Court Discovery - 2. Interrogatories
Interrogatories – Md. Rule 2-421
Interrogatories are written questions relating to the lawsuit that you serve on the opposing party. Unlike depositions, which may be directed toward non-parties, interrogatories may only be served on parties to the lawsuit. The Maryland Rules of Civil Procedure allow you to serve thirty interrogatories against each party. If you have two opponents, you may serve thirty interrogatories to one opponent and another thirty to the other opponent. In addition, the Maryland Rules do not require you to serve all interrogatories to a party at the same time. You may serve some interrogatories to a party at the beginning of the lawsuit and the remainder at a later time, provided you do not exceed thirty interrogatories total for each opponent.
When drafting interrogatories, make sure that each interrogatory asks a single question. An interrogatory that contains many subparts may count as multiple interrogatories. There is an exception to this Rule: the “form” interrogatories found in the Appendix to the Maryland Rules. Md. Rule 2-421(a) specifically states that “[e]ach form interrogatory contained in the Appendix” counts as a single interrogatory. You should consult the form interrogatories and use those applicable to your case.
A list of form interrogatories split into multiple topics can be found here: Circuit Court Form Interrogatories.
Interrogatories are generally served early in the lawsuit. Some plaintiffs will even serve interrogatories with the Complaint. The party answering must serve the answers to interrogatories either thirty days after the service of the interrogatories or fifteen days after the date on which the party’s initial pleading or motion is due, whichever is later. The answers must be made in writing under oath and signed by the party that is answering. See Md. Rule 2-421(b). You must answer the interrogatories as much as you can. If you object to any interrogatory, you should state the reasons for your objection in the answer to the interrogatory. See the links below for a discussion of valid objections.