Maryland State Court Discovery - Interrogatories

MARYLAND STATE COURT DISCOVERY — INTERROGATORIES

Overview

This template provides a comprehensive set of interrogatories for use in Maryland Circuit Court civil actions. Maryland Rule 2-421 governs interrogatories to parties and imposes a cumulative limit of 30 interrogatories (including all subparts) per party. Each discrete subpart counts as a separate interrogatory, regardless of how questions are grouped. Responses are due within 30 days after service, or within 15 days after the date on which the responding party's initial pleading or motion is required, whichever is later. Answers must be made in writing, under oath, and signed by the answering party.

CASE CAPTION

IN THE CIRCUIT COURT FOR [________________________________] COUNTY, MARYLAND

[________________________________]

Civil Action No.: [________________________________]

[________________________________],
Plaintiff,

v.

[________________________________],
Defendant.

ATTORNEY INFORMATION

Attorney for Propounding Party:

PLAINTIFF'S [____] SET OF INTERROGATORIES TO DEFENDANT

TO: [________________________________] ("Responding Party"), by and through counsel of record.

I. INTRODUCTORY STATEMENT

Plaintiff [________________________________] ("Propounding Party"), by and through undersigned counsel, pursuant to Maryland Rule 2-421, hereby propounds the following Interrogatories to Defendant [________________________________] ("Responding Party"). These Interrogatories must be answered fully, separately, and under oath in accordance with the following requirements:

Response Deadline: The Responding Party must serve written answers and any objections within thirty (30) days after service of these Interrogatories, or within fifteen (15) days after the date on which the Responding Party's initial pleading or motion is required, whichever is later. Md. Rule 2-421(b).

Interrogatory Limit: This set contains [____] interrogatories, including all discrete subparts. Under Md. Rule 2-421(a), a party may serve a cumulative total of not more than thirty (30) interrogatories on any other party. Each interrogatory, however grouped, combined, or arranged, and even though subsidiary or incidental to or dependent upon other interrogatories, is counted separately.

Sanctions for Failure to Respond: Failure to respond adequately and timely may result in sanctions under Md. Rule 2-433, including an order compelling answers, an award of reasonable expenses and attorney fees, or other relief as the court deems just. The court may also enter orders precluding the disobedient party from supporting or opposing designated claims or defenses, or striking pleadings.

II. DEFINITIONS

For purposes of these Interrogatories, the following terms shall have the meanings set forth below, regardless of capitalization, tense, or singular/plural usage:

A. "Action" means the above-captioned civil matter, including all claims, defenses, counterclaims, cross-claims, and third-party claims.

B. "Communication" means every manner or form of disclosure, exchange, or transfer of information, whether oral, written, electronic, or otherwise, including but not limited to letters, memoranda, emails, text messages, instant messages, social media posts or messages, telephone calls, voicemails, video conferences, and in-person conversations.

C. "Concerning," "Relating to," or "Regarding" means referring to, describing, evidencing, constituting, reflecting, mentioning, or in any way logically or factually connected with the matter discussed.

D. "Date" means the exact day, month, and year, or if the exact date is unknown, the best approximation thereof.

E. "Document" has the meaning set forth in Md. Rule 2-401(f) and includes electronically stored information ("ESI") of every kind and in every format, including but not limited to writings, drawings, graphs, charts, photographs, audio recordings, video recordings, digital files, metadata, databases, and any other data compilations from which information can be obtained.

F. "Identify" or "Identification" means:

• (i) When used with reference to a natural person: state the person's full legal name, present or last known home address, present or last known telephone number, present employer and job title, and relationship (if any) to any party in this Action.
• (ii) When used with reference to a business entity: state its full legal name, form of organization, state of incorporation or organization, principal place of business, and the identity of a representative with knowledge of the subject matter.
• (iii) When used with reference to a Document: state its title or description, date, author(s), recipient(s), type (e.g., letter, email, report), Bates number(s) or other identifying mark(s), and present custodian or location.
• (iv) When used with reference to a Communication: state the date, participants, mode (e.g., telephone, email, in-person), and substance of the Communication.

G. "Person" means any natural person, corporation, partnership, limited liability company, association, governmental entity, or any other legal entity.

H. "Subject Incident" means the events, transactions, or occurrences that form the basis of the claims alleged in the Complaint, occurring on or about [__/__/____] at [________________________________].

I. "You," "Your," or "Responding Party" means the party to whom these Interrogatories are directed, together with all present and former agents, employees, officers, directors, representatives, attorneys, and any other Person acting or purporting to act on its behalf.

J. "Relevant Period" means [__/__/____] through the present date, unless otherwise specified in a particular Interrogatory.

III. INSTRUCTIONS AND GENERAL PROVISIONS

A. Oath Requirement. Each answer must be made separately, fully, and under oath by the party or, if the party is a public or private corporation, partnership, association, or governmental agency, by an officer or agent who shall furnish information available to the party. Md. Rule 2-421(b).

B. Objections. If You object to any Interrogatory or portion thereof, state the specific legal and factual grounds for each objection. Boilerplate or blanket objections are improper and insufficient. Answer all non-objected portions fully. Md. Rule 2-421(b).

C. Privilege Claims. If any information is withheld based on any claim of privilege, work-product protection, or other immunity from disclosure, You must:

• (i) Expressly state the specific claim being asserted;
• (ii) Provide a privilege log identifying each item withheld with sufficient detail to enable assessment of the claim without revealing the privileged material itself, consistent with Md. Rule 2-402(f).

D. Continuing Duty to Supplement. Pursuant to Md. Rule 2-401(e)(4), these Interrogatories are continuing in nature. You must promptly amend or supplement Your answers if You learn that they were incomplete or incorrect when made, or have become incomplete or incorrect.

E. Sources of Information. Your answers shall include all information within Your possession, custody, or control, including information available through Your agents, representatives, attorneys, and all other persons acting on Your behalf.

F. Construction. The singular includes the plural and vice versa. The masculine includes the feminine and vice versa. The terms "and" and "or" shall be construed inclusively (i.e., "and/or"). Words shall be given their broadest reasonable meaning consistent with ordinary usage and the Maryland Rules.

G. Time Period. Unless otherwise specified, each Interrogatory covers the Relevant Period as defined above.

H. Production of Business Records. If the answer to any Interrogatory may be derived from Your business records and the burden of ascertaining the answer is substantially the same for the Propounding Party as for the Responding Party, You may specify the records from which the answer may be derived and afford the Propounding Party reasonable opportunity to examine and copy them. Md. Rule 2-421(c).

IV. GENERAL INTERROGATORIES

INTERROGATORY NO. 1:
Identify each Person who participated in preparing, reviewing, or supplying information for Your answers to these Interrogatories, and for each such Person, state the specific Interrogatory or Interrogatories to which that Person contributed information.

INTERROGATORY NO. 2:
State Your full legal name, all former names or aliases, date of birth, current home address, current employer, job title, and business address.

INTERROGATORY NO. 3:
Describe in complete detail Your version of how the Subject Incident occurred, including the chronological sequence of events, all actions taken by each participant, all statements made at or near the scene, and the weather, lighting, and road or surface conditions at the time and place of the incident.

INTERROGATORY NO. 4:
Identify every Person known to You who witnessed, observed, or has knowledge of any facts relating to the Subject Incident, and for each such Person, state:

• (a) Their contact information;
• (b) A summary of the facts known to that Person;
• (c) Whether that Person has provided any written or recorded statement; and
• (d) Whether You intend to call that Person as a witness at trial.

INTERROGATORY NO. 5:
State in detail the factual basis for each affirmative defense asserted in Your Answer, including identification of all Documents, Communications, and Persons upon which You rely to support each defense.

INTERROGATORY NO. 6:
Identify all photographs, videos, audio recordings, surveillance footage, or other media depicting the Subject Incident or its aftermath, and for each, state:

• (a) The date created;
• (b) The creator or source;
• (c) The current custodian and location;
• (d) A description of its content; and
• (e) Whether You intend to introduce it as an exhibit at trial.

INTERROGATORY NO. 7:
Identify every expert witness You have retained or expect to call at trial, and for each, provide:

• (a) Full name, business address, and professional qualifications;
• (b) The subject matter on which the expert is expected to testify;
• (c) The substance of the facts and opinions to which the expert is expected to testify;
• (d) A summary of the grounds for each opinion; and
• (e) A list of all cases in which the expert has testified at trial or by deposition within the preceding four years.

INTERROGATORY NO. 8:
Describe all insurance agreements under which any person, firm, or corporation carrying on an insurance business may be liable to satisfy all or part of a judgment entered in this Action, or to indemnify or reimburse for payments made to satisfy such judgment, including for each:

• (a) The insurer name and address;
• (b) The policy number;
• (c) Effective dates and coverage period;
• (d) Per-occurrence and aggregate limits of liability;
• (e) Deductible or self-insured retention amounts;
• (f) Applicable exclusions or endorsements; and
• (g) Any reservation of rights letters issued.

INTERROGATORY NO. 9:
State the total amount of damages or other monetary relief You contend should be applied against Plaintiff's claims, and describe the methodology, computations, and all Documents used to arrive at each category of offset, credit, or reduction.

INTERROGATORY NO. 10:
If You contend that any third party is wholly or partially responsible for the injuries or damages alleged by Plaintiff, identify each such third party and describe in detail the factual and legal basis for such contention, including all Documents and Communications supporting the claim.

INTERROGATORY NO. 11:
Describe all Communications between You and Plaintiff (or any agent or representative of Plaintiff) during the Relevant Period Concerning the subject matter of this Action, stating for each:

• (a) The date;
• (b) The participants;
• (c) The mode of Communication (e.g., telephone, email, letter, in-person); and
• (d) The substance of the Communication.

INTERROGATORY NO. 12:
Identify and describe all internal investigations, reviews, audits, or inquiries conducted by You or at Your direction Relating to the allegations in the Complaint or the Subject Incident, including:

• (a) The date(s) of the investigation;
• (b) The individuals who conducted or participated in the investigation;
• (c) The conclusions or findings reached; and
• (d) Any corrective or remedial actions taken as a result.

INTERROGATORY NO. 13:
Describe with particularity every category of electronically stored information ("ESI") maintained by You that is potentially relevant to this Action, including:

• (a) The types of ESI (email, text messages, databases, etc.);
• (b) The custodians and data sources;
• (c) Retention policies and periods;
• (d) Any steps taken to preserve such ESI since the date You first anticipated litigation; and
• (e) Whether any potentially relevant ESI has been destroyed, lost, or overwritten, and if so, the circumstances thereof.

INTERROGATORY NO. 14:
State whether You have destroyed, discarded, lost, or otherwise disposed of any Documents Concerning this Action or the Subject Incident at any time after You first anticipated litigation, and if so, for each such Document, identify:

• (a) The type of Document;
• (b) The date range covered;
• (c) The date and circumstances of destruction, loss, or disposal; and
• (d) The Person(s) responsible.

INTERROGATORY NO. 15:
If You contend that Plaintiff failed to mitigate damages, state all facts upon which You base that contention, identify all Persons with knowledge of such facts, and identify all Documents supporting the contention.

INTERROGATORY NO. 16:
If You contend that any claim asserted by Plaintiff is barred by the statute of limitations, laches, or any other time-based defense, identify each statute, rule, or doctrine relied upon and state all facts supporting its applicability.

INTERROGATORY NO. 17:
Identify all Persons (other than retained experts) who possess knowledge of facts relevant to this Action, and for each such Person provide:

• (a) Full name and contact information;
• (b) A summary of the relevant knowledge possessed; and
• (c) The Person's relationship to any party in this Action.

V. CASE-SPECIFIC INTERROGATORIES

The following blank interrogatories are provided for case-specific questions. Number them consecutively following the General Interrogatories above. Ensure the cumulative total of all interrogatories, including subparts, does not exceed 30 under Md. Rule 2-421(a).

INTERROGATORY NO. [____]:
[________________________________]

INTERROGATORY NO. [____]:
[________________________________]

INTERROGATORY NO. [____]:
[________________________________]

INTERROGATORY NO. [____]:
[________________________________]

INTERROGATORY NO. [____]:
[________________________________]

VI. VERIFICATION / OATH

I, [________________________________], being first duly sworn, depose and say that I am the [________________________________] (title/position) 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[____].

Signature: [________________________________]

Printed Name: [________________________________]

Title/Position: [________________________________]

Party Name: [________________________________]

NOTARIZATION (Optional — Maryland does not require notarization of discovery answers, but practitioners may include it for added evidentiary weight)

STATE OF [________________________________] )
) ss:
COUNTY OF [________________________________] )

Subscribed and sworn to before me this [____] day of [________________________________], 20[____].

Notary Public: [________________________________]

My Commission Expires: [__/__/____]

[NOTARY SEAL]

VII. CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this [____] day of [________________________________], 20[____], a true and correct copy of the foregoing Plaintiff's [____] Set of Interrogatories to Defendant was served upon:

Counsel for Defendant:

Method of Service: (Select all that apply)

☐ Hand delivery
☐ First-class United States mail, postage prepaid
☐ Certified mail, return receipt requested
☐ Electronic service via MDEC (Maryland Electronic Courts)
☐ Facsimile transmission to [________________________________]
☐ Email to [________________________________]
☐ Other: [________________________________]

Service was made in accordance with Md. Rule 1-321.

Signature: [________________________________]

[________________________________], Esquire
Bar Number: [________________________________]
Counsel for Plaintiff

VIII. PRACTICE NOTES AND GUIDANCE

A. Maryland Interrogatory Limits and Counting Rules

Under Md. Rule 2-421(a), a party may serve a cumulative total of not more than 30 interrogatories on any other party. Interrogatories are counted separately regardless of how they are grouped, combined, or arranged, and even though subsidiary or incidental to or dependent upon other interrogatories. This means each discrete subpart counts as a separate interrogatory toward the 30-question limit.

District Court: In Maryland District Court, the limit is reduced to 15 interrogatories. Md. Rule 3-421.

B. Response Deadlines and Extensions

• Standard deadline: 30 days after service. Md. Rule 2-421(b).
• Early service: If interrogatories are served before the responding party's initial pleading or motion is due, the response deadline is 15 days after the initial pleading/motion deadline, whichever is later.
• Extensions: Parties may stipulate to extensions of time under Md. Rule 2-401(c). Court approval may be required if the extension would affect other scheduling order deadlines.

C. Business Records Option

Under Md. Rule 2-421(c), if the answer to an interrogatory may be derived from the responding party's business records, and the burden of deriving the answer is substantially the same for the propounding party as for the responding party, the responding party may specify the records from which the answer can be derived and provide a reasonable opportunity to examine and copy them.

D. Corporate Party Responses

When the responding party is a corporation, partnership, or governmental agency, an officer or agent must furnish information available to the entity. See Md. Rule 2-412 regarding answers by corporate officers.

E. Motion to Compel

If the responding party fails to answer or provides evasive or incomplete answers, the propounding party may file a motion to compel under Md. Rule 2-432. The motion must include a certification that the movant made a good-faith effort to resolve the dispute before filing.

F. Sanctions

Under Md. Rule 2-433, sanctions for failure to comply with discovery orders may include:
☐ An order that designated facts be taken as established
☐ An order refusing to allow the disobedient party to support or oppose claims or defenses
☐ An order striking pleadings or parts thereof
☐ An order staying proceedings until compliance
☐ An order dismissing the action or entering a default judgment
☐ An order holding the party in contempt of court
☐ An award of reasonable expenses, including attorney fees

G. E-Discovery Considerations

Maryland has adopted rules addressing ESI. Under Md. Rule 2-402(b), ESI is discoverable from any source. Parties should discuss ESI protocols early in the case, including preservation obligations, search methodologies, format of production, and cost allocation.

H. Form Interrogatories

Maryland provides standard form interrogatories in the Appendix to the Maryland Rules. Practitioners may use these forms as a starting point and supplement with case-specific questions, provided the total does not exceed 30.

IX. SOURCES AND REFERENCES

• Maryland Rule 2-421 — Interrogatories to Parties
• Maryland Rule 2-401 — General Provisions Governing Discovery
• Maryland Rule 2-402 — Scope of Discovery
• Maryland Rule 2-403 — Protective Orders
• Maryland Rule 2-412 — Answers by Corporate Officers
• Maryland Rule 2-432 — Motions to Compel Discovery
• Maryland Rule 2-433 — Sanctions for Failure to Make Discovery
• Maryland Rule 1-321 — Service of Pleadings and Other Papers
• Maryland Rule 3-421 — Interrogatories to Parties (District Court)
• Maryland Courts Self-Help Center — Discovery in Circuit Court (https://www.mdcourts.gov/courthelp/discoverycircuitcourt)

This template is designed for use in Maryland Circuit Court civil actions. Practitioners should verify all rule citations against the current version of the Maryland Rules before filing. Local court rules and individual judge preferences may impose additional requirements. Always consult with a qualified Maryland attorney before using this template in a legal proceeding.