Maryland District Court Interrogatories

Interrogatories are written questions that must be answered by a party under oath and in writing.  They are a way for the parties to a Maryland lawsuit to find out information prior to trial and narrow the issues for trial.  Both drafting and responding to interrogatories involves great tactical considerations.  Interrogatories can only be served between parties.  The interrogatories do not need to be approved by the Court before being served, meaning that it is up to the responding party to protect itself from overbroad or inappropriate interrogatories.  Lawyers who regularly engage in litigation develop the experience necessary to gauge whether an interrogatory would be ruled overbroad by a court or whether a response provides enough information to avoid sanction. 

An important thing to keep in mind when responding to interrogatories is that you only need to provide the information that you know or can find from the materials in your possession.  For example, a common interrogatory will ask something to the effect of “list every conversation you ever had about this matter, including the date, parties to that conversation, and what was discussed.”  There could have been dozens of conversations, and remembering and writing down all of the details and would take a long time.  Instead, a common response is simply “there were numerous conversations, the details of which cannot be recalled at this time.”  The challenge with that response though is that if there is some important conversation that needs to be brought up in court, not mentioning it in the response to the interrogatory could affect whether it can be discussed in court.  So the overall approach is to disclose the important facts that you intend to rely on, but don’t feel like you have to respond to every aspect of every question if the information isn’t available to you. 

In Maryland District Court, under Maryland Rule 3-421, interrogatories are available in matters seeking more than $5,000.00.  The deadlines for sending interrogatories to the other side are pretty early after a lawsuit is filed. Unless the Court orders otherwise in response to a motion, the plaintiff (the party who filed the lawsuit) has to serve the interrogatories by mailing them to the defendant within 10 days after the court sets a trial date after a notice of intention to defend is filed, and the defendant has to send any interrogatories to the plaintiff within 10 days after the deadline for filing a notice of intention to defend. 

If interrogatories are served in a Maryland District Court case, the response is due 15 days after the interrogatories are served, or 20 days if the interrogatories are served with the complaint at the beginning of the lawsuit.  If interrogatories are served and not answered, the serving party can make a motion to compel a response and for sanctions, often seeking to win the case if the other side does not answer the interrogatories. 

If you are party to a Maryland district court case and you would like to serve interrogatories or help answering interrogatories that were served on you, Civil Justice's Limited Scope Project may be a good fit for you.  When an attorney agrees to provide you with limited scope representation, it means that the attorney will do certain things for you but will not take on all of the responsibility for your case.  Civil Justice has a group of private Maryland attorneys who can provide limited scope assistance with drafting interrogatories or responses to interrogatories, without needing to charge you for representing you all the way through the litigation.  The cost of preparing answers to interrogatories in district court matters is generally between $250.00 and $500.00, but it can be more if the matter is particularly complex.  To be referred to a Civil Justice member who can help, please fill out this online intake form or call us at (410) 706-0174.  

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