Interrogatories are part of the pretrial discovery portion of a lawsuit.

Under Maryland law, parties can send Interrogatories — written questions — to the other party seeking information about issues in the case. In the District Court, you can send 15 Interrogatories, and in the Circuit Court you can serve up to 30 Interrogatories on your opponent(s).

When I file a new suit on behalf of my injured client, I routinely serve Interrogatories on the defendant. This way, I get the defendant’s version of the case as soon as possible. These are sample interrogatories for a plaintiff in a Maryland car accident case in the Circuit Court.

I also serve a Request for Production of Documents which requires the defendant(s) to produce relevant documents. This is a sample Request for Production of Documents that a plaintiff can serve along with the original court papers in a Maryland car accident case in the Circuit Court.

After the suit papers are served on the defendant, you can expect the defendant’s lawyer to send Interrogatories for you to answer. Most cases are defended by in-house counsel employed by the various insurance companies. They each have a set of Interrogatories that they send in every case. So, based on the insurance company involved, we have a good idea what Interrogatories they will ask.

Normally, the defense counsel also sends a Request for Production of Documents.

Here’s how we handle the defendant’s Interrogatories in our office.

After I send the interrogatories to you, your job is to draft complete and specific answers and send your draft answers to the Interrogatories back to me.

Then, I will use the information that you provided, other information that I have developed during the case and my professional judgment to draft proposed answers to the Interrogatories.

Finally, you will have to review, approve and sign the Answers to Interrogatories under oath.

All of this must be completed within time limits established by the rules of procedure. Failure to complete the answers to interrogatories within the required times can result in serious penalties, even including dismissal of you case.

Answering interrogatories carefully and accurately is critical to your case. An incorrect or incomplete answer can have devastating effects on your case, so you must give the answers the time and attention that this fact requires.

What’s the purpose of interrogatories?

Parties send interrogatories not only to discover the details of another party’s case but also to pin down the other party to a version of the facts in the case.

Then, if you testify in court inconsistently with your Answers to Interrogatories, you can be confronted with the prior inconsistent Interrogatory answer, casting doubt on your competency or credibility.

If you have any questions about Interrogatories, please contact me.