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A party may object to interrogatories when being required to answer would result in ?unwarranted annoyance, embarrassment, or oppression, or undue burden and expense.? (Code Civ. Proc., § 2023.010(c).) 4. Unreasonably cumulative or undue burden and expense.
Contention interrogatories are specifically permitted under CCP §2030.010(b). You are generally limited to 35 Special Interrogatories, although there are circumstances where you may use more (CCP §2030.030 and CCP §2030.050). You can do both Form Interrogatories and Special Interrogatories.
Maryland Rule 2-421 ? Interrogatories in Maryland Interrogatories are formal questions in writing to the adverse party requiring written responses under oath. Parties may serve thirty interrogatories to each other and typically have thirty days to respond in Maryland.
The response shall answer each interrogatory separately and fully in writing under oath, or shall state fully the grounds for refusal to answer any interrogatory. The response shall set forth each interrogatory followed by its answer.
Each interrogatory must be answered separately and fully in writing under oath unless it is objected to, in which event the grounds for objection must be stated and signed by the attorney making it.