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Rule 2-633.Discovery in aid of enforcement

Circuit Court · Last amended August 1, 2020 · Last verified July 13, 2026

In one sentenceGives a judgment creditor tools — depositions, interrogatories, document requests, and sworn examinations — to track down a debtor's assets after judgment.

Full Text of Rule 2-633

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(a) Methods. — Except as otherwise provided in Rule 2-634, a judgment creditor may obtain discovery to aid enforcement of a money judgment (1) by use of depositions, interrogatories, and requests for documents, and (2) by examination before a judge or an examiner as provided in section (b) of this Rule.
(b) Examination before a judge or an examiner. —
(1) Generally. — Subject to section (c) of this Rule, on request of a judgment creditor filed no earlier than 30 days after entry of a money judgment, the court where the judgment was entered or recorded shall issue an order requiring the appearance for examination under oath before a judge or examiner of
(A) the judgment debtor, or (B) any other person who may have property of the judgment debtor, be indebted for a sum certain to the judgment debtor, or have knowledge of any concealment, fraudulent transfer, or withholding of any assets belonging to the judgment debtor.
(2) Order. —
(A) The order shall specify when, where, and before whom the examination will be held and that failure to appear may result in (i) the issuance of a body attachment directing a law enforcement officer to take the person served into custody and bring that person before the court and (ii) the person served being held in contempt of court.
(B) The order shall be served upon the judgment debtor or other person in the manner provided by Rule 2-121, but no body attachment shall issue in the event of a non-appearance absent a determination by the court that (i) the person to whom the order was directed was personally served with the order in the manner described in Rule 2-121 (a)(1) or (3), or (ii) that person has been evading service willfully, as shown by a particularized affidavit based on personal knowledge of a person with firsthand knowledge.
(3) Sequestration. — The judge or examiner may sequester persons to be examined, with the exception of the judgment debtor.
(c) Subsequent Examinations. — After an examination of a person has been held pursuant to section (b) of this Rule, a judgment creditor may obtain additional examinations of the person in accordance with this section. On request of the judgment creditor, if more than one year has elapsed since the most recent examination of the person, the court shall order a subsequent appearance for examination of the person. If less than one year has elapsed since the most recent examination of the person, the court may require a showing of good cause.

Amendment History

Amended Apr. 7, 1986, effective July 1, 1986; Nov. 12, 2003, effective Jan. 1, 2004; December 7, 2015, effective January 1, 2016; May 15, 2019, effective July 1, 2019; amended June 29, 2020, effective August 1, 2020.

Committee Note & Source

Committee note. The discovery permitted by this Rule is in addition to the discovery permitted before the entry of judgment, and the limitations set forth in Rules 2-411 (d) and 2-421 (a) apply separately to each. Thus, a second deposition of an individual previously deposed before the entry of judgment may be taken after the entry of judgment without leave of court. A second post-judgment deposition of that individual, however, would require leave of court. Melnick v. New Plan Realty, 89 Md. App. 435 (1991). Furthermore, leave of court is not required under Rule 2-421 to serve interrogatories on a judgment debtor solely because 30 interrogatories were served upon that party before the entry of judgment.

Cross references. See Rule 1-361.

Cross references. Code, Courts Article, §§ 6-411 and 9-119.

Source. This Rule is derived as follows:

Section (a) is derived from former Rule 627.

Section (b) is in part new and in part derived from former Rule 628 b.

Section (c) is new.

Plain-English Summary

Winning a money judgment doesn't tell a creditor where the debtor's assets are. Rule 2-633 lets the creditor use the same discovery tools available before trial — depositions, interrogatories, and requests for documents — to find out, plus a distinct post-judgment tool: a sworn examination before a judge or an examiner.

To get an examination, the creditor waits at least 30 days after entry of the judgment and then requests one. The court orders the debtor, or anyone else who may hold the debtor's property, owe the debtor money, or know about concealed or fraudulently transferred assets, to appear and answer questions under oath. The order has to spell out when, where, and before whom the examination will happen, and it has to warn that skipping it can lead to a body attachment or contempt. A body attachment can issue for a no-show only if the person was personally served with the order or the creditor shows, by a detailed affidavit from someone with firsthand knowledge, that the person has been willfully evading service. The judge or examiner can also sequester witnesses waiting to be examined — everyone except the judgment debtor.

Examinations aren't a one-time event. After a first examination, the creditor can ask for another. If more than a year has passed since the last one, the court orders it as a matter of course; if less than a year has passed, the court can require the creditor to show good cause first. This post-judgment discovery runs on its own track — separate from whatever discovery happened before judgment, with its own limits on things like the number of depositions and interrogatories. Maryland courts have applied that separation to mean a witness deposed once before judgment can be deposed again after judgment without needing the court's permission, though a second post-judgment deposition of that same witness does require leave.

Frequently Asked Questions

How soon after winning a judgment can I request a debtor examination?

No earlier than 30 days after entry of the money judgment.

Who can be ordered to appear for examination — just the debtor?

No. The court can also order anyone else who may hold the debtor's property, owe the debtor a sum certain, or know about concealed, fraudulently transferred, or withheld assets.

What happens if the person ordered to appear doesn't show up?

They risk a body attachment directing a law enforcement officer to bring them before the court, and can be held in contempt. But a body attachment can issue only if the person was personally served with the order, or the creditor shows by a detailed affidavit that the person has been willfully evading service.

Can a creditor ask the same person to sit for a second post-judgment examination?

Yes. If more than a year has passed since the last examination, the court orders a new one on request. If less than a year has passed, the court can require the creditor to show good cause.

Does this discovery count against the limits from before the judgment?

No. Post-judgment discovery under this rule runs separately from pre-judgment discovery, with its own limits on depositions and interrogatories.

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: debtor examination marylanddiscovery in aid of enforcementpost judgment discovery interrogatoriesbody attachment judgment debtorexamination before an examiner maryland