All parties are limited to 30 interrogatories (written questions) sent to any other one party in the case. You can view sample interrogatories in the Maryland Rules of Procedure. Maryland Rule of Procedure 2-421 controls how and when interrogatories are sent and responded to in circuit court cases.
Under the Maryland Rules, you must provide the opposing party with your discovery answers within either 30 days after service of the request or 15 days after the date on which the party's initial pleading or motion is required, whichever is later.
A motion to compel asks the court to order the opposing party to respond to discovery by a certain date. These motions are typically acts of last resort, which you should save for when your opponent fails to respond to any of your requests.
Keep in mind that 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.
Rule 2-421 - Interrogatories to Parties (a) Availability; Number. Any party may serve written interrogatories directed to any other party. Unless the court orders otherwise, a party may serve one or more sets having a cumulative total of not more than 30 interrogatories to be answered by the same party.
Your answers to the interrogatories should usually be short, clear, and direct and should answer only the question that is being asked. This is not the time to set out your entire case or defense to the other side. Take the time to make sure your answers are correct and truthful.
Some of the simple tactics to follow while filing a motion to compel: Act in good Faith. The State and Federal Rules of Civil Procedure require parties to meet and confer before bringing a motion to compel. Thorough Knowledge of the Case. Limit citing voluminous authorities. Avoid Personal Attacks.
Motions to compel are often necessary to set the tone in your case and acquire the documents and information you need to win your case. Grounds: When a party who has propounded discovery believes the responses are inadequate, the propounding party may move for a motion to compel a further response.
Requirements for Motion – The following requirements must be fulfilled for a proper motion to compel interrogatories: Identify the interrogatories in question by name and set number. CRC 3.1345(d). Meet and Confer Declaration Required. CCP 2030.300(b). Separate Statement Required. CRC 3.1345(a)(2).