Objections to Interrogatories: Federal Rules and Examples
Objections to Interrogatories: Federal Rules and Examples
Legal content overseen by Nathan Walter, Esq., attorney licensed in California (State Bar No. 313299).
Under the Federal Rules of Civil Procedure, objections to interrogatories must be served within 30 days after service of the interrogatories unless a stipulation or court order sets a different time, and each ground must be stated with specificity (Rule 33(b)(2) and (b)(4)).
Any part of an interrogatory that is not objected to must still be answered separately, fully and under oath.
This guide covers federal procedure only: the rules, the facts that support each common ground, three invented defense-side examples that pair an objection with an answer, and the mistakes that weaken an objection.
What are objections to interrogatories?
An objection to an interrogatory is a written statement, served with the answers, that the responding party is not fully answering a question for a stated reason such as scope, burden or privilege. A denial responds on the facts; an objection challenges the question or part of it.
Under Rule 33(a)(2), an interrogatory “may relate to any matter that may be inquired into under Rule 26(b),” so most objections come back to the scope and limits in Rule 26(b). Our guides to interrogatories in discovery and federal discovery responses cover the wider process, and our reference on objections across written discovery compares other request types.
This guide is written for defense-side litigators and paralegals responding in employment and premises-liability cases. Briefpoint offers discovery workflows for defense firms.
Federal rules for objections to interrogatories
Deadline, specificity and waiver
Rule 33 sets the response deadline and the standard for objections:
- Deadline: “The responding party must serve its answers and any objections within 30 days after being served with the interrogatories.” A shorter or longer time may be stipulated to under Rule 29 or ordered by the court (Rule 33(b)(2)).
- Specificity and waiver: “The grounds for objecting to an interrogatory must be stated with specificity. Any ground not stated in a timely objection is waived unless the court, for good cause, excuses the failure” (Rule 33(b)(4)).
Answers under oath and separate signatures
Rule 33(b)(3) says each interrogatory must, “to the extent it is not objected to, be answered separately and fully in writing under oath.”
When the responding party is a corporation, partnership, association or governmental agency, the answers are made “by any officer or agent, who must furnish the information available to the party” (Rule 33(b)(1)(B)). The person who makes the answers signs them, and the attorney who objects signs any objections (Rule 33(b)(5)).
Count discrete subparts, not just numbered questions
Unless otherwise stipulated or ordered by the court, a party may serve “no more than 25 written interrogatories, including all discrete subparts.” Leave to serve more may be granted “to the extent consistent with Rule 26(b)(1) and (2)” (Rule 33(a)(1)). The rule text does not define a discrete subpart, and this guide does not propose a test for one.
Common grounds and the facts that support them
None of these entries guarantees that a court will sustain an objection.
Relevance, proportionality and overbreadth
Rule: Rule 26(b)(1) allows discovery of “any nonprivileged matter that is relevant to any party’s claim or defense and proportional to the needs of the case,” considering:
- the importance of the issues at stake in the action;
- the amount in controversy;
- the parties’ relative access to relevant information;
- the parties’ resources;
- the importance of the discovery in resolving the issues; and
- whether the burden or expense of the proposed discovery outweighs its likely benefit.
Facts to state: the claims or defenses at issue, the facility, time period, person or subject the interrogatory reaches, and why that requested information falls outside the relevant and proportional scope of discovery. The words “all” or “every” in a question do not by themselves show overbreadth.
Undue burden and cumulative discovery
Rule: the last factor above weighs burden or expense against likely benefit. Under Rule 26(b)(2)(C), the court, on motion or on its own, “must limit the frequency or extent of discovery” if it determines that:
- the discovery is unreasonably cumulative or duplicative, or can be obtained from some other source that is more convenient, less burdensome, or less expensive;
- the party seeking discovery has had ample opportunity to obtain the information by discovery in the action; or
- the proposed discovery is outside the scope permitted by Rule 26(b)(1).
Facts to state: the records or systems that would have to be searched, the work involved and the limited benefit to the case. A documented burden gives a court something to weigh; the word “burdensome” alone does not. Rule 26(b)(2)(C) states what the court must do, not an exemption from answering.
Unclear terms and disputed premises
Rule: the passages of Rules 33 and 26 quoted in this guide do not set out a separate test for vague or ambiguous questions.
Drafting practice: an answer can identify the unclear term, state the interpretation used and answer on that basis, consistent with Rule 33(b)(3). The same practice applies to a question built on a premise the responding party disputes: the answer can state the dispute and respond within it.
Privilege and work product
Rule: Rule 26(b)(1) reaches only “nonprivileged” matter. Trial-preparation materials are addressed separately in Rule 26(b)(3)(A): “Ordinarily, a party may not discover documents and tangible things that are prepared in anticipation of litigation or for trial by or for another party or its representative.” Subject to Rule 26(b)(4), they may be discovered if they are otherwise discoverable under Rule 26(b)(1) and the requesting party “shows that it has substantial need for the materials to prepare its case and cannot, without undue hardship, obtain their substantial equivalent by other means.” If a court orders discovery of them, it “must protect against disclosure of the mental impressions, conclusions, opinions, or legal theories of a party’s attorney or other representative concerning the litigation” (Rule 26(b)(3)(B)).
The substantial-need exception sits in the trial-preparation provision, and its text does not extend it to every privilege claim. Attorney-client privilege elements are outside this guide.
Facts to state: a party that withholds information on either basis “must: (i) expressly make the claim; and (ii) describe the nature of the documents, communications, or tangible things not produced or disclosed” in a manner that “will enable other parties to assess the claim” without revealing protected information (Rule 26(b)(5)(A)). A privilege log is one way to convey that description; the rule text prescribes no format.
Confidential information and protective orders
Rule: confidentiality is not the same as privilege. Under Rule 26(c)(1), the court “may, for good cause, issue an order to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense.” Rule 26(c)(1)(G) lists an order “requiring that a trade secret or other confidential research, development, or commercial information not be revealed or be revealed only in a specified way.”
Facts to state: the nature of the information and why unconditional disclosure would cause that harm. A motion for a protective order under Rule 26(c)(1) “must include a certification that the movant has in good faith conferred or attempted to confer with other affected parties in an effort to resolve the dispute without court action.”
Examples of objections to interrogatories
The scenarios and responses below are invented for illustration. They are not court-approved forms, and each depends on its own invented facts.
Narrowing an unrelated time period and location
A former shift supervisor at an employer’s Dayton distribution center sues over his March 31, 2024 termination. The employer operates 40 facilities. Interrogatory No. 6 asks Defendant to identify every employee disciplined at any facility from January 1, 2010 through March 31, 2024, and the reason for each discipline.
Objection: Defendant objects to Interrogatory No. 6 under Rule 26(b)(1) as to facilities other than the Dayton distribution center and as to any period before January 1, 2022. Plaintiff’s claim concerns his termination by the Dayton operations manager. The interrogatory reaches discipline imposed by other managers at 39 other facilities over fourteen years, which is not tied to a pleaded claim or defense and is not proportional to the needs of the case. Defendant is not providing information outside that scope.
Answer: From January 1, 2022 through March 31, 2024, four employees at the Dayton distribution center received discipline, all issued by the Dayton operations manager: Alex Reed and Jordan Lee for attendance, Casey Morgan for a safety violation, and Taylor Brooks for insubordination.
The objection names the claim and the facilities and dates it excludes, so the other side can see what is not being answered, and the answer covers the unobjected portion as Rule 33(b)(3) requires. Whether a court would accept January 1, 2022 as the cutoff depends on the pleadings; the example shows structure, not a safe harbor.
Explaining a disproportionate records inquiry
A customer sues a grocery chain over a fall in one aisle of Store 112 on October 3, 2024. The chain operates 140 stores. Interrogatory No. 9 asks Defendant to identify every wet-floor complaint, incident report and claim at any store from January 1, 2015 through October 3, 2024.
Objection: Defendant objects to Interrogatory No. 9 under Rule 26(b)(1) as to stores other than Store 112 because the burden and expense of the discovery outweigh its likely benefit. Defendant keeps incident reports in store-level logs, and responding for every store would require manual review of logs for 140 stores across the ten calendar years 2015–2024, or 1,400 annual store logs. Plaintiff’s claim concerns one aisle on one date.
Answer: From January 1, 2015 through October 3, 2024, Store 112 received two wet-floor complaints before Plaintiff’s fall: Morgan Ellis’s June 14, 2023 complaint about aisle 4, recorded in incident report 112-2023-0614, and Avery Chen’s January 9, 2024 complaint about aisle 7, recorded in incident report 112-2024-0109. Neither concerned the aisle where Plaintiff fell. On October 3, 2024, Plaintiff reported the fall at issue in this action, and manager Jamie Patel completed the standard incident report for that fall. Apart from those matters, Store 112 had no wet-floor complaints, incident reports or claims during the stated period.
The burden statement identifies the source, the volume and the comparison to the claim. The quantities are hypothetical, and the court decides whether the burden outweighs the benefit.
Separating protected material from discoverable facts
In the same case, Interrogatory No. 12 asks Defendant to describe every investigation of the fall, including the substance of each witness statement and each investigator’s conclusions.
Objection: Defendant objects to Interrogatory No. 12 to the extent it seeks the protected contents of a four-page memorandum dated October 9, 2024, prepared in anticipation of litigation by investigator Riley Park at Defendant’s counsel’s direction. The memorandum summarizes interviews with Store 112 employees Sam Rivera and Drew Quinn and records the investigator’s litigation-related conclusions. Defendant claims trial-preparation protection under Fed. R. Civ. P. 26(b)(3) and provides this description under Rule 26(b)(5)(A). Defendant withholds the memorandum’s protected contents, not the underlying facts about the fall.
Answer: On October 3, 2024, Store 112 manager Jamie Patel inspected the aisle and completed Defendant’s standard incident report. Rivera reported seeing liquid in the aisle shortly before the fall; Quinn reported placing a warning cone after the fall. Patel concluded that the source of the liquid was unknown. On October 9, 2024, Park interviewed Rivera and Quinn at counsel’s direction and prepared the memorandum described above. These were the only investigations.
The objection makes the claim expressly and describes the withheld item without revealing what it says, as Rule 26(b)(5)(A) asks. The example involves trial-preparation material under Rule 26(b)(3), not attorney-client privilege. Whether a document was prepared in anticipation of litigation is a question of its facts.
Mistakes that weaken an interrogatory objection
General reservations instead of request-specific grounds
Rule 33(b)(4) speaks of the grounds for objecting “to an interrogatory,” stated “with specificity.” A paragraph of general objections at the front of a response set does not tie a ground to a particular interrogatory, and a ground not stated in a timely objection is waived unless the court, for good cause, excuses the failure.
Treating contention questions or multiple clauses as automatically improper
Rule 33(a)(2) provides that an interrogatory “is not objectionable merely because it asks for an opinion or contention that relates to fact or the application of law to fact.” The 1970 Advisory Committee Note adds that interrogatories “may not extend to issues of ‘pure law,’ i.e., legal issues unrelated to the facts of the case.” Multiple clauses raise a counting question under Rule 33(a)(1), not a categorical ban on compound questions.
Treating incomplete discovery as an extension
Under Rule 33(a)(2), the court “may order that the interrogatory need not be answered until designated discovery is complete, or until a pretrial conference or some other time.” Incomplete discovery does not itself extend the response deadline; the timing changes through a court order or a stipulation under Rule 29, as Rule 33(b)(2) provides.
For interrogatories touching expert issues, Rule 26(a)(2)(D) states that disclosures are made “at the times and in the sequence that the court orders,” so the court’s expert schedule is the first thing to check. This guide does not cover expert-discovery protections.
State rules
For state-court cases, separate guides cover California interrogatory responses, Texas interrogatory responses, Florida interrogatory responses and New York interrogatory responses. Use the guide for the relevant jurisdiction rather than treating this federal overview as a state-court response guide.
Draft interrogatory responses with Briefpoint
Briefpoint drafts responses and objections to interrogatories, requests for production and requests for admission. Output is editable in Microsoft Word, and attorneys keep final review, so objections and answers can be revised before service. The attorney decides which grounds the facts support, and a draft is not a legal conclusion or a compliance guarantee. Briefpoint supports all 50 states and 98 federal courts. Attorneys still review the draft against the governing rules and the facts of the case.
When an answer or objection turns on identifying documents, Autodoc can support that document work. It finds responsive documents, adds page-level Bates citations and builds a Bates-numbered production package. The response draft remains subject to attorney review.
Book a demo to see how Briefpoint drafts interrogatory responses and objections for defense matters.
See Briefpoint in this short demo:
FAQs About Objections to Interrogatories
What are common objections to interrogatories?
Common grounds include relevance and proportionality under Rule 26(b)(1), undue burden, trial-preparation protection under Rule 26(b)(3) and (b)(5), and confidential information, addressed through a protective order under Rule 26(c)(1). Each ground must be stated with specificity under Rule 33(b)(4), and any part not objected to must be answered under oath.
Can you object to an interrogatory and still answer part of it?
Yes. Rule 33(b)(3) requires each interrogatory, “to the extent it is not objected to,” to be answered separately and fully in writing under oath. An objection to one clause or time period leaves the rest to be answered, and the attorney who objects signs the objection under Rule 33(b)(5).
Are general objections to interrogatories enough?
Rule 33(b)(4) requires the grounds for objecting to an interrogatory to be stated with specificity, and a ground not stated in a timely objection is waived unless the court excuses the failure for good cause. A general statement at the front of the responses does not tie a ground to a particular interrogatory.
Can an interrogatory ask for a legal conclusion?
Sometimes. Under Rule 33(a)(2), an interrogatory is not objectionable merely because it asks for an opinion or contention relating to fact or the application of law to fact. The 1970 Advisory Committee Note says interrogatories may not extend to issues of “pure law,” meaning legal issues unrelated to the case’s facts.
What is a compound interrogatory, and can you object to it?
A compound interrogatory combines several questions under one number. Rule 33(a)(1) limits a party to 25 written interrogatories “including all discrete subparts,” unless stipulated or ordered, and the court may grant leave to serve more. The rule text does not define a discrete subpart or ban compound questions.
The information provided on this website does not, and is not intended to, constitute legal advice; instead, all information, content, and materials available on this site are for general informational purposes only. Information on this website may not constitute the most up-to-date legal or other information. This website contains links to other third-party websites. Such links are only for the convenience of the reader, user or browser. Readers of this website should contact their attorney to obtain advice with respect to any particular legal matter. No reader, user, or browser of this site should act or refrain from acting on the basis of information on this site without first seeking legal advice from counsel in the relevant jurisdiction. Only your individual attorney can provide assurances that the information contained herein – and your interpretation of it – is applicable or appropriate to your particular situation. Use of, and access to, this website or any of the links or resources contained within the site do not create an attorney-client relationship between the reader, user, or browser and website authors, contributors, contributing law firms, or committee members and their respective employers.
READ MORE




