Service on an out-of-state defendant can be made by certified mail through the Secretary of the Commonwealth. At least 6 weeks should be allowed for the return date when service is requested through the Secretary of the Commonwealth.
(a) Interrogatories are written questions prepared by a party to an action that are sent to any other party in the action to be answered under oath. The interrogatories below are form interrogatories approved for use in civil cases.
You can object to an interrogatory if the information sought is known by the requesting party or available to both parties equally. For example, you should raise this objection if the answers are publicly available or in a third-party's custody or control.
You have to respond to interrogatories in writing to the best of your ability. If you do not answer an interrogatory question, and then the other side learns that you did in fact know the answer, it could have a negative impact on your case at trial.
Parties may obtain discovery regarding any matter, not privileged, which is relevant to the subject matter involved in the pending action, whether it relates to the claim or defense of the party seeking discovery or to the claim or defense of any other party, including the existence, description, nature, custody, ...
The original form interrogatories and signed proof of service should be retained for your records. If the other party does not respond to your requests, you may use these documents to support a motion to have the court compel responses.
(d) Answers. — Each interrogatory must be answered separately and fully in writing under oath, except to the extent it is objected to, in which event the reasons for any objection must be stated with specificity. Any part of an interrogatory that is not objected to must be answered.
(g) Limitation on Interrogatories. No party shall serve upon any other party, at any one time or cumulatively, more than thirty written interrogatories, including all parts and sub-parts without leave of court for good cause shown.