First Set Interrogatories

In most cases, a deponent cannot refuse to answer a question at a deposition unless the answer would reveal privileged or irrelevant private information or the court previously ordered that the information cannot be revealed (source). However, there are certain types of questions that do not have to be answered.

You must answer each interrogatory separately and fully in writing under oath, unless you object to it. You must explain why you object. You must sign your answers and objections.

(1) Number. 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. Leave to serve additional interrogatories may be granted to the extent consistent with Rule 26(b)(1) and (2).

The number of questions included in an interrogatory is usually limited by court rule. For example, under the Federal Rules of Civil Procedure, each party may only ask each other party 25 questions via interrogatory unless the court gives permission to ask more.

Motions to Compel If a party doesn't respond to interrogatories or requests for production, then the party seeking those answers must file a motion to compel with the court. If the court grants the motion to compel, then the party who objected or failed to answer must then do so.

You can object to an interrogatory if the information sought is known by the requesting party or available to both parties equally. For example, you should raise this objection if the answers are publicly available or in a third-party's custody or control.

An interrogatory is part of the discovery process before the trial.The interrogatory is considered to be conducted under oath. Any information provided on it will be seriously reviewed by the court and the lawyers involved. Your lawyer can ask any question that he or she wants on the form.

So, can you refuse to answer interrogatories? The answer is, no, you may not. You must answer a Rule 33 interrogatory within 30 days of being served with it. That answer must either permit inspection of the requested information or object to the production of the information for a specific reason.