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Begin by explaining that the case has reached the discovery stage and what that means. Something like this: At this stage of the pending action, all parties are subject to procedures called ?discovery? that allow each party to obtain information and documents relevant to the case.
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.
You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.
Usually, lawyers use interrogatories to obtain detailed information about persons, corporations, facts, witnesses, and identity and locations of records and documents. Court rules usually limit the number of questions included in an interrogatory.
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.
You have 30 days to respond to Form Interrogatories. If you were served by mail, you typically have 35 days from the date of mailing to respond. In eviction (unlawful detainer) cases the time is much shorter. In eviction cases you have 5 days to respond, or typically 10 days from the date of mailing if served by mail.
Special Interrogatories Cannot be Used to Request Documents. The proper mechanism to have a party produce a document is an inspection demand.
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.