(a) Availability; number. — Any party may serve written interrogatories directed to any other party. Unless the court orders otherwise, a party may serve one or more sets having a cumulative total of not more than 30 interrogatories to be answered by the same party. Interrogatories, however grouped, combined, or arranged and even though subsidiary or incidental to or dependent upon other interrogatories, shall be counted separately. Each form interrogatory contained in the Appendix to these Rules shall count as a single interrogatory.
Rule 2-421.Interrogatories to parties
Circuit Court · Last amended January 1, 2008 · Last verified July 13, 2026
In one sentenceLets any party send written interrogatories to any other party, capped at 30 questions unless the court allows more, with answers due under oath within 30 days.
Full Text of Rule 2-421
(b) Response. — The party to whom the interrogatories are directed shall serve a response within 30 days after service of the interrogatories or within 15 days after the date on which that party’s initial pleading or motion is required, whichever is later. The response shall answer each interrogatory separately and fully in writing under oath, or shall state fully the grounds for refusal to answer any interrogatory. The response shall set forth each interrogatory followed by its answer. An answer shall include all information available to the party directly or through agents, representatives, or attorneys. The response shall be signed by the party making it.
(c) Option to produce business records. — When (1) the answer to an interrogatory may be derived or ascertained from the business records, including electronically stored information, of the party upon whom the interrogatory has been served or from an examination, audit, or inspection of those business records or a compilation, abstract, or summary of them, and (2) the burden of deriving or ascertaining the answer is substantially the same for the party serving the interrogatory as for the party served, and (3) the party upon whom the interrogatory has been served has not already derived or ascertained the information requested, it is a sufficient answer to the interrogatory to specify the records from which the answer may be derived or ascertained and to afford to the party serving the interrogatory reasonable opportunity to examine, audit, or inspect the records and to make copies, compilations, abstracts, or summaries. A specification shall be in sufficient detail to permit the interrogating party to locate and to identify, as readily as can the party served, the records from which the answer may be ascertained.
(d) Use. — Answers to interrogatories may be used at the trial or a hearing to the extent permitted by the rules of evidence.
Amendment History
Amended Mar. 22, 1991, effective July 1, 1991; June 7, 1994, effective Oct. 1, 1994; Jan. 18, 1996, effective July 1, 1996; Nov. 12, 2003, effective Jan. 1, 2004; Dec. 4, 2007, effective Jan. 1, 2008.
Committee Note & Source
Source. This Rule is derived as follows:
Section (a) is derived in part from former Rule 417 a 1 and 2 and is in part new.
Section (b) is derived from former Rule 417 b 1 and 2.
Section (c) is derived from former Rule 417 f and the 1980 version of Fed. R. Civ. P. 33 (c).
Section (d) is derived from former Rule 417 d.
Plain-English Summary
Interrogatories are written questions one party sends another, and the answers come back signed and under oath. Rule 2-421 sets the ground rules: a party may serve one set or several, but the total count across all sets may not exceed 30 questions unless the court permits more. The rule guards against gamesmanship by counting every sub-part separately, no matter how a question is grouped, combined, or nested inside another. Any form interrogatory pulled from the Rules appendix counts as one question toward that limit, even though it may cover several topics.
The responding party gets 30 days from service to answer, or 15 days from when its first pleading or motion is due, whichever date lands later. Each answer must address its interrogatory separately, in writing, and under oath, or explain fully why the party refuses to answer. Where the information sits in business records and pulling it out would be just as much work for one side as the other, the responding party can point to the records instead of writing out an answer, so long as it gives the requesting party a real chance to examine and copy them. Answers gathered this way, and any answer under the rule generally, can be used at trial or a hearing to the extent the rules of evidence allow.
Frequently Asked Questions
How many interrogatories can I send in a Maryland circuit court case?
Thirty, counted cumulatively across every set you serve on the same party, unless the court orders a higher number. A question with several sub-parts counts as more than one interrogatory, and even a question described as subsidiary to another gets its own count. A form interrogatory taken from the Rules appendix, however, counts as just one question regardless of how many topics it touches.
How long does a party have to answer interrogatories?
Thirty days after service, or 15 days after the party's initial pleading or motion is due, whichever comes later. The response has to restate each interrogatory before answering it, be signed by the answering party, and be made under oath.
Can a party answer by pointing to its business records instead of writing out an answer?
Yes, when the answer can be derived from the responding party's business records (including electronically stored information) and figuring it out would take the requesting party about as much work as it would take the responding party. The responding party has to identify the records specifically enough that the other side can locate the answer, and give a real opportunity to examine, copy, or audit them.
Can interrogatory answers be used at trial?
Yes, to the extent the rules of evidence allow. Because they're sworn statements from a party, they carry weight beyond ordinary discovery paperwork.
What happens if a party won't answer an interrogatory?
The responding party has to state fully the grounds for refusing. If the requester disagrees, Rule 2-432 governs a motion to compel, and Rule 2-431 requires a certificate showing a good-faith attempt to resolve the dispute before the court will even take it up.
Source & verification. Rule text, Committee Note, Source note, and
amendment history are reproduced verbatim from the Maryland Rules, adopted by the
Supreme Court of Maryland. Last verified July 13, 2026. ·
Official source
Also known as: interrogatories marylandROGsROGwritten interrogatoriesmaryland discovery questions30 interrogatories rule