Common objections to interrogatories include irrelevance, disproportionality to the needs of the case, overbreadth, undue burden, vagueness, attorney-client privilege, work product protection, improper legal-conclusion questions, and exceeding the 25-question limit under Federal Rule of Civil Procedure 33. Any of these can protect you from having to answer, but only if you state the grounds with specificity and serve your objections within 30 days. Miss either requirement and the objection is usually waived, no matter how strong it would have been.
Grounds That Actually Work
Not every objection carries the same weight. Some are near-automatic winners when properly supported. Others get routinely overruled because parties assert them reflexively without doing the work to explain why they apply.
Irrelevance
You can object when an interrogatory seeks information that has nothing to do with any claim or defense in the case. Under the current federal standard, discovery is limited to nonprivileged matters relevant to a party’s claims or defenses and proportional to the needs of the case. A question about your college grades in a breach-of-contract dispute over a construction project has no connection to any issue the court will decide.
The old formulation you may still see quoted, “reasonably calculated to lead to the discovery of admissible evidence,” was replaced in the 2015 amendments. Judges now apply a relevance-plus-proportionality test, which gives them more tools to rein in requests that technically touch the subject matter but would cost more than the information is worth.
Disproportionate to the Needs of the Case
A question can be relevant and still objectionable if answering it would be disproportionate to what the case actually requires. Courts weigh the importance of the issues at stake, the amount in controversy, the parties’ relative access to the information, the importance of the discovery in resolving the dispute, and whether the burden or expense outweighs the likely benefit. An interrogatory demanding a complete accounting of every transaction over a 15-year period in a $10,000 dispute is the kind of request judges regularly strike down on proportionality grounds.
Overly Broad or Unduly Burdensome
These two objections overlap with proportionality but target different problems. An interrogatory is overly broad when it lacks meaningful boundaries in time, subject matter, or scope. Questions that use “all,” “every,” or “any and all” without limiting the request to a relevant period or topic are the classic examples. Asking for “all communications you have ever had regarding the product” casts a net so wide it becomes meaningless.
An interrogatory is unduly burdensome when the sheer effort required to answer it is unreasonable given the stakes. If one question would require reviewing tens of thousands of documents over several weeks in a modest case, the burden likely outweighs the benefit. Courts expect you to explain that burden with specifics. Stamping “unduly burdensome” on a response without quantifying the cost or time involved is the fastest way to lose the point on a motion to compel.
Vague or Ambiguous
An interrogatory must be clear enough that a reasonable person knows what is being asked. If the question uses undefined terms, fails to specify a time period, or could be read multiple ways, you can object. Asking someone to “describe all communications related to the incident” without identifying which people, what time frame, or what type of communication leaves the respondent guessing.
Courts expect good faith here. If you can reasonably figure out what a question is asking despite imperfect drafting, many judges will expect you to answer it and note your interpretation rather than refuse. Objecting to an obviously clear question on vagueness grounds tends to backfire.
Privileged Information
Certain communications are legally protected from disclosure. Attorney-client privilege is the most commonly invoked, covering confidential communications between a lawyer and client made for the purpose of obtaining legal advice. “What did your attorney tell you about the contract?” is a textbook example.
Other recognized privileges include doctor-patient, spousal, and in some contexts clergy-penitent. When asserting any privilege objection, you must identify the specific privilege being claimed and provide enough information about the communication for the court and opposing counsel to evaluate whether the privilege applies, without revealing the protected content itself.
Work Product Protection
The work product doctrine shields materials prepared by or for an attorney in anticipation of litigation, including research notes, mental impressions, case strategy memos, and investigative summaries.1Cornell Law School. Rule 33 Interrogatories to Parties An interrogatory asking for your lawyer’s internal analysis of the case’s weak points falls squarely within it.
Unlike attorney-client privilege, work product protection is not absolute. A court can order disclosure if the requesting party shows a substantial need for the materials and cannot obtain equivalent information through other means without undue hardship. Even then, courts almost always protect an attorney’s mental impressions, opinions, and legal theories, which sit at the core of the doctrine.
Contention Questions
This is where many parties get the objection wrong. The common wisdom is that interrogatories cannot ask for legal conclusions, but Rule 33 is more nuanced. It states 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.1Cornell Law School. Rule 33 Interrogatories to Parties So “State all facts supporting your claim that the defendant breached the contract” is perfectly proper, even though it asks you to connect facts to a legal theory.
What remains objectionable is a question asking for a pure legal opinion with no factual component, like “Do you believe the statute of limitations has run?” Courts also have discretion to defer contention interrogatories until later in the case, sometimes ordering that they need not be answered until other discovery is complete or a pretrial conference has occurred. If you receive one early, requesting a deferral is often more effective than a blanket objection.
Exceeding the 25-Question Cap
Rule 33 caps each party at 25 written interrogatories, including all discrete subparts, unless the parties agree otherwise or a judge grants permission to exceed it.1Cornell Law School. Rule 33 Interrogatories to Parties A question that packs multiple unrelated inquiries into a single numbered interrogatory can be challenged as exceeding the limit through its subparts. Courts look at whether each subpart is truly discrete, meaning it asks for different information rather than narrowing a single topic. If opposing counsel sends what looks like 20 interrogatories but the subparts push the real count well past 25, that is a valid basis to object to the extras.
How to Make an Objection That Holds Up
An objection means nothing if it is not properly made. Rule 33 requires the grounds for each objection to be stated with specificity.1Cornell Law School. Rule 33 Interrogatories to Parties Boilerplate language like “Defendant objects on the grounds that this interrogatory is overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence” is the single most common mistake in discovery practice. Courts routinely treat these generic objections as no objection at all.
The responding party must serve answers and objections within 30 days after being served with the interrogatories, though the parties can agree to a different deadline or a judge can set one.1Cornell Law School. Rule 33 Interrogatories to Parties Any objection not raised in that timely response is waived unless a court excuses the failure for good cause. Missing this deadline can forfeit every objection you had, even meritorious ones.
When only part of a question is objectionable, you must answer the rest. If an interrogatory asks for both privileged and non-privileged information, object to the privileged portion and provide the non-privileged answer.1Cornell Law School. Rule 33 Interrogatories to Parties Refusing to answer entirely because one aspect is problematic is a sure way to draw a motion to compel.
The federal rules also split signing duties. The party answering (the actual person, not the lawyer) signs the substantive answers, because those are made under oath. The attorney signs any objections, taking personal responsibility for their legal basis.1Cornell Law School. Rule 33 Interrogatories to Parties Getting this backward creates procedural headaches that are entirely avoidable.
One alternative worth knowing: when an answer can be found by reviewing your business records, Rule 33(d) lets you produce those records instead of writing out the answer, but only if the burden of extracting the information would be roughly the same for either side.1Cornell Law School. Rule 33 Interrogatories to Parties You must identify the specific records in enough detail that the requesting party can find what it needs. Dumping boxes of unsorted documents and saying “it’s in there somewhere” does not satisfy the rule.
What Happens If the Other Side Pushes Back
Before anyone files a motion over a discovery dispute, the federal rules require the parties to try to resolve it themselves. A motion to compel must include a certification that the moving party conferred or attempted to confer in good faith with the opposing side.2Cornell Law School. Rule 37 Failure to Make Disclosures or to Cooperate in Discovery Sanctions Filing a motion without this step can result in the motion being denied outright, and the court may order the filing party to pay the other side’s expenses.
In practice, the meet and confer is a phone call or exchange of letters where both sides explain their positions. Many disputes resolve at this stage: the requesting party narrows an overly broad question, or the responding party agrees to answer after the scope is clarified. Judges take the good-faith requirement seriously and look unfavorably on parties who treat it as a box-checking exercise.
When the meet and confer fails, the party seeking answers can file a motion to compel. The judge evaluates the objections and can sustain them, overrule them and order a full response, or narrow the question and require an answer to the revised version.
The financial stakes are real. If the motion is granted, the court must generally order the objecting party or their attorney to pay the moving party’s reasonable expenses, including attorney’s fees.2Cornell Law School. Rule 37 Failure to Make Disclosures or to Cooperate in Discovery Sanctions The reverse is also true: if the motion is denied, the party who filed it can be ordered to pay the other side’s costs in opposing it. That two-way fee-shifting gives both sides a strong incentive to be reasonable before anything reaches the judge.
If a party disobeys a court order compelling answers, sanctions escalate. A judge can prohibit the disobedient party from supporting or opposing specific claims, from introducing certain evidence at trial, or can strike pleadings, stay proceedings, or enter a default judgment.2Cornell Law School. Rule 37 Failure to Make Disclosures or to Cooperate in Discovery Sanctions The court must also order the disobedient party to pay the other side’s reasonable expenses and attorney’s fees caused by the failure. Courts impose these penalties regularly, and the consequences can be case-ending.