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You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.
If your case is an unlimited civil case (over $25,000) you may ask up to 35 special interrogatories, but may ask more with a declaration explaining the need for additional requests and a statement that the request is not done for an improper purpose.
Usually, lawyers use interrogatories to obtain detailed information about persons, corporations, facts, witnesses, and identity and locations of records and documents.
A party shall not propound more than forty (40) interrogatories to any other party without leave of court. Upon motion, and for good cause shown, the court may increase the number of interrogatories that a party may serve upon another party.
Generally, interrogatories are objectionable if they seek information that is not within the scope of discovery as defined in Maryland Rule 402 or Federal Rule 26(b). These are typically requests that are not relevant, unduly burdensome, broad, vague, privileged. or protected by the work product doctrine.
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.
However, you can object to interrogatories that call for legal conclusions. You can also object to questions if they are not at all related to the court case. To object, you need to write out the reasons for the objection instead of answering the question.
Interrogatories to Parties (a) In General. (1) Availability. Unless otherwise stipulated or ordered by the court, a party may serve on any other party no more than 25 written interrogatories, including all discrete subparts.