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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.
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.
The Interrogatory Is Vague, Overly Broad, and Unduly Burdensome. In some cases, the plaintiff may object because the claim is too broad and not directly related to uncovering evidence. This might fly, as long as they can explain why.
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.
Make it a lead-off ?general objection.? Object to anything that is not relevant to the ?subject matter? (no longer the standard) or not likely to lead to admissible evidence (no longer the standard). Don't say if anything is being withheld on the basis of the objection. Use boilerplate wording from form files.