Section 3.33 Grounds for Objection to Interrogatories

• Library: Discovery 2015

Rule 57.01(c)(3) requires that the reasons for the objection be stated. The objections should provide the specific reasons why the interrogatories are objectionable and should not be framed in the following conclusory language:

• Wholly immaterial, irrelevant, and incompetent

• Burdensome, constitute an annoyance, oppression, and undue expense

• Are not proper interrogatories and are speculative and seek information that cannot properly be required in answers to interrogatories

• Seek information that is as readily available to the opposing party

• Are an attempt to force the answering party to prepare the opponent’s case

State ex rel.Norfolk & W. Ry. Co. v. Dowd, 448 S.W.2d 1, 3 (Mo. banc 1969); see also Apco Oil Corp. v. Certified Transp., Inc., 46 F.R.D. 428, 430 (W.D. Mo. 1969).

The following include some of the grounds that may be used to object to interrogatories in the appropriate situation, but they should be coupled with the reasons the objection applies in that particular case:

• The information sought is not relevant to the subject matter of the pending action.

• The information is privileged.

• The question is not reasonably calculated to lead to the discovery of admissible evidence.
• The question seeks...