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Massachusetts Interrogatories Sample

State:
Massachusetts
Control #:
MA-221-MV
Format:
Word; 
Rich Text
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Description Interrogatories Sample

This is a sample set of 28 Interrogatories from Defendant to Plaintiff for use in connection with a vehicle incident, such as an automobile accident. You should only use this form as a guide and delete questions not relevant to your case, as well as add questions you or your client want to ask the Defendant based upon the facts of your case.
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FAQ

(1) Number. Unless otherwise stipulated or ordered by the court, a party may serve on any other party no more than 25 written interrogatories, including all discrete subparts. Leave to serve additional interrogatories may be granted to the extent consistent with Rule 26(b)(1) and (2).

The rules of practice require that responses to interrogatories are provided under oath, which in your case, would be taken by a Notary.

The 25-interrogatory limit applies to all parts and sub-parts of a single question (so 1a, 1b, and 1c count as three interrogatories). For civil lawsuits in state court, the allowable number of interrogatories varies, so check your state's civil procedure rules or ask your personal injury lawyer.

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.

Also, Federal Rules of Civil Procedure have placed twenty-five questions per party limitations on the use of interrogatories, but there is no numerical limit in FRCP on the requests for admission (unless specified differently in Local Rules of the state, which most states do have).

§2 allows the court to alter the limits of discovery on the number of depositions, interrogatories, and document requests if it determines that the discovery sought is overly burdensome, redundant, unnecessary, or disproportionately difficult to produce with respect to the importance of the case or specific issue.

No party shall serve upon any other party as of right more than thirty interrogatories, including interrogatories subsidiary or incidental to, or dependent upon, other interrogatories, and however the same may be grouped or combined; but the interrogatories may be served in two or more sets, as long as the total number

Make it a lead-off general objection. Object to anything that is not relevant to the subject matter (no longer the standard) or not likely to lead to admissible evidence (no longer the standard). Don't say if anything is being withheld on the basis of the objection. Use boilerplate wording from form files.

For Federal Court, you want to look at the Federal Rules of Civil Procedure, particularly rules 33 and 34. Doc requests don't require verifications, and you serve only objections, you don't need verifications for interrogatory responses.

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Massachusetts Interrogatories Sample