IN THE [COURT] FOR [COUNTY], MARYLAND
CIVIL ACTION NO. [____]
[PLAINTIFF NAME], )
Plaintiff, )
)
v. ) PLAINTIFF’S [FIRST] SET OF
) INTERROGATORIES TO
[DEFENDANT NAME], ) [PARTY NAME]
Defendant. )
)
PLAINTIFF’S [FIRST] SET OF
INTERROGATORIES TO [PARTY NAME]
Plaintiff, by and through undersigned counsel and pursuant to Md. Rule 2-421, hereby
propounds the following Interrogatories to [Party Name], to be answered fully, in writing,
and under oath within thirty (30) days after service hereof. The total number of
interrogatories, including discrete subparts, does not exceed thirty (30) as required by Md.
Rule 2-421(a).
[// GUIDANCE: Use “FIRST,” “SECOND,” etc. to track multiple discovery rounds. If prior
sets were served, renumber accordingly and obtain leave of court if total exceeds 30.]
I. DEFINITIONS
For purposes of these Interrogatories, the following capitalized terms shall have the
meanings set forth below. All other capitalized terms carry the meaning given by context
or the Maryland Rules of Civil Procedure.
- “Action” means the above-captioned civil matter, including all claims, defenses,
counterclaims, and third-party claims. - “Plaintiff” refers to [Plaintiff Name], together with all present and former officers,
directors, employees, agents, attorneys, and other representatives. - “Defendant” refers to [Defendant Name], together with all present and former officers,
directors, employees, agents, attorneys, and other representatives. - “You” or “Your” means the party to whom these Interrogatories are directed and all
persons acting or purporting to act on that party’s behalf. - “Document” is defined as in Md. Rule 2-401(f) and includes electronically stored
information (“ESI”) of every kind. - “Identify” (with respect to a natural person) means to provide the person’s full name,
present or last known address, telephone number, employer, and job title at all
relevant times. - “Subject Incident” means the events alleged in the Complaint to have occurred on or
about [DATE] at [LOCATION].
II. INSTRUCTIONS & GENERAL PROVISIONS
A. Answer each Interrogatory separately, fully, and under oath in accordance with
Md. Rule 2-421(b).
B. If You object to any Interrogatory or portion thereof, state the specific grounds for
objection. Answer all non-objected portions.
C. If any information is withheld under claim of privilege, immunity, or protection,
You must:
(i) expressly state the claim being asserted, and
(ii) provide a privilege log identifying the nature of the information withheld,
consistent with Md. Rule 2-402(f).
D. These Interrogatories are continuing. Pursuant to Md. Rule 2-401(e)(4), You must
promptly amend or supplement Your answers if You learn they were incomplete or
incorrect when made, or have become incomplete or incorrect.
E. Where knowledge, information, or documents are requested, such request includes
knowledge, information, or documents within the possession, custody, or control of
You or Your agents, attorneys, representatives, and all other persons acting on
Your behalf.
F. Singular includes plural and vice versa; masculine includes feminine and vice versa.
G. The time period covered is [TIMEFRAME] unless otherwise specified.
III. INTERROGATORIES
Interrogatory No. 1
Identify every person known to You who witnessed the Subject Incident and state each
person’s contact information and a summary of the facts expected to be testified to.
Interrogatory No. 2
Describe in complete detail Your version of how the Subject Incident occurred,
including the sequence of events, actions taken by each participant, and any statements
made at the scene.
Interrogatory No. 3
Identify all photographs, videos, audio recordings, or other media depicting the Subject
Incident or its aftermath, stating for each: (a) the date created; (b) the creator; (c) the
current custodian; and (d) whether You intend to introduce it at trial.
Interrogatory No. 4
State the name, specialty, and address of every expert You intend to call at trial and
summarize the substance of the facts and opinions to which each expert is expected to
testify, as well as the grounds for each opinion.
Interrogatory No. 5
Detail all insurance agreements under which any person carrying on an insurance
business may be liable to satisfy all or part of a judgment in this Action or to indemnify
or reimburse for payments made to satisfy the judgment, including policy numbers,
coverage limits, and applicable exclusions.
[// GUIDANCE: Continue numbering up to Interrogatory No. 30 as needed.
Be mindful that each discrete subpart counts toward the 30-interrogatory limit under
Md. Rule 2-421(a).]
IV. VERIFICATION
I, _______, being first duly sworn, depose and say
that I am the [POSITION/TITLE] of [PARTY NAME] and that I have read the foregoing
answers to Interrogatories and know the contents thereof, and that the same are true and
correct to the best of my knowledge, information, and belief.
Executed on this _ day of __, 20___.
[NAME]
[POSITION/TITLE]
[PARTY NAME]
STATE OF _ )
) ss:
COUNTY OF ______ )
Subscribed and sworn to before me this _ day of __, 20___.
Notary Public
My Commission Expires: ____
[// GUIDANCE: Maryland does not require notarization of discovery answers, but many
practitioners include it for added evidentiary weight. Remove if undesired.]
V. CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this _ day of __, 20___, a copy of the foregoing
Plaintiff’s [First] Set of Interrogatories to [Party Name] was served upon:
[Opposing Counsel Name]
[Law Firm]
[Address]
[Email Address]
via [method of service] in accordance with Md. Rule 1-321.
[ATTORNEY NAME] (#__)
[Law Firm]
[Address]
[Phone]
[Email]
Counsel for Plaintiff
[// GUIDANCE: 1) Tailor the Definitions and Interrogatories to the factual allegations and
legal theories of your case. 2) Confirm the proper court caption format for the Maryland
Circuit or District Court in which the Action is pending. 3) Use MD-specific E-Service
protocols if the court’s electronic filing system so requires. 4) Verify county-specific
differentiators such as the inclusion of ADR statements where mandated. 5) Where
corporate parties are involved, substitute an officer verification or corporate designee
pursuant to Md. Rule 2-412.]
[END OF DOCUMENT]