Rule 13-6. Interrogatories; In General

(a) In any civil action, in any probate appeal, or in any administrative appeal where the judicial authority finds it reasonably probable that evidence outside the record will be required, any party may serve in accordance with Sections 1012 through 10-17 written interrogatories, which may be in electronic format, upon any other party to be answered by the party served. Written interrogatories may be served upon any party without leave of the judicial authority at any time after the return day. Except as provided in subsection (d) or where the interrogatories are served electronically as provided in Section 10-13 and in a format that allows the recipient to electronically insert the answers in the transmitted document, the party serving interrogatories shall leave sufficient space following each interrogatory in which the party to whom the interrogatories are directed can insert the answer. In the event that an answer requires more space than that provided on interrogatories that were not served electronically and in a format that allows the recipient to electronically insert the answers in the transmitted document, the answer shall be continued on a separate sheet of paper which shall be attached to the completed answers.

(b) Interrogatories may relate to any matters which can be inquired into under Sections 13-2 through 13-5, and the answers may be used at trial to the extent permitted by the rules of evidence. In all personal injury actions alleging liability based on the operation or ownership of a motor vehicle or alleging liability based on the ownership, maintenance or control of real property, or in actions claiming a loss of consortium or uninsured/underinsured motorist coverage benefits, the interrogatories shall be limited to those set forth in Forms 201, 202, 203, 208, 210, 212, 213 and/or 214 of the rules of practice, unless upon motion, the judicial authority determines that such interrogatories are inappropriate or inadequate in the particular action. These forms are set forth in the Appendix of Forms in this volume. Unless the judicial authority orders otherwise, the frequency of use of interrogatories in all actions except those for which interrogatories have been set forth in Forms 201, 202, 203, 208, 210, 212, 213, 214, 218, 220 and/or 221 of the rules of practice is not limited.

(c) In all actions alleging medical negligence, the interrogatories shall be limited to: (1) those set forth in Forms 218, 220, and 221 of the rules of practice and contained in the Appendix of Forms in this volume to which no objections shall be allowed and (2) twenty additional interrogatories as of right, which may not contain subparts. The party to whom the additional twenty as of right interrogatories are directed may file specific, individual objections to each additional as of right interrogatory.

(d) The standard interrogatories in civil actions, including standard and as of right additional interrogatories in medical negligence actions, are intended to address discovery needs in most cases in which their use is mandated, but they do not preclude any party from moving for permission to serve such additional discovery as may be necessary in any particular case as contemplated by Section 13-2.

(e) In lieu of serving the interrogatories set forth in Forms 201, 202, 203, 208, 210, 212, 213, 214, 218, 220, and/or 221 of the rules of practice on a party who is represented by counsel, the moving party may serve on such party a notice of interrogatories, which shall not include the actual interrogatories to be answered, but shall instead set forth the number of the Practice Book form containing such interrogatories and the name of the party to whom the interrogatories are directed. The party to whom such notice is directed shall in his or her response set forth each interrogatory immediately followed by that party's answer thereto.

(f) The party serving interrogatories or the notice of interrogatories shall not file them with the court.

(g) Unless leave of court is granted, the instructions to Forms 201 through 203 are to be used for all nonstandard interrogatories.

Committee Notes

(P.B. 1978-1997, Sec. 223.) (Amended June 28, 1999, to effect Jan. 1, 2002; amended June 30, 2008, to take effect Jan. 1, 2009; amended June 14, 2013, to take effect Jan. 1, 2014; amended June 24, 2016, to take effect Jan. 1, 2017; amended June 23, 2017, to take effect Jan. 1, 2018; amended June 11, 2021, to take effect Jan. 1, 2022.)