Toolbox
Minnesota Interrogatory Objections
From LegalLanding
Below are various interrogatory objections you can make when the other party serves your client with interrogatories, made pursuant to Rule 33 of the Minnesota Rules of Civil Procedure. The language is worded as if a Defendant is responding to the interrogatories, however, it is intended for either party.
- This first objection is a general objection for all responses and should be used at the beginning of your Answer to Interrogatories but below the caption.
- "By the following responses, Defendant does not waive in any way, and does not intend to waive:
- All questions as to competency, relevance, materiality, privilege, and admissibility as evidence of these responses or their subject matter, for any purpose, in this or any other proceeding;
- The right to object to the use of these responses or the subject matter thereof, on any ground, in this or any other proceeding;
- The right to object to any request or demand for further response to these or any other discovery requests relating to the subject matter of the responses herein; and
- The right at any time to revise, correct, add to or modify any of these responses."
- "Defendant objects to these interrogatories to the extent they seek information protected by the attorney‑client privilege or work product doctrine, as defined by rule, statue, or common law."
- "Defendant objects to these interrogatories to the extent they attempt to impose an obligation to supplemental responses beyond that contained in the Rules of Civil Procedure."
- "Defendant objects to these interrogatories to the extent Plaintiff already possesses or has equal access to the information sought."
- "Defendant objects to these interrogatories to the extent they attempt to expand the definition of terms to be substantially broader than the requirement of the Rules of Civil Procedure. Defendant's responses shall be limited to the requirements of the Rules of Civil Procedure."
- The foregoing objection can be made for any one of the reasons provided, but sometimes you may use them in conjunction (i.e. the interrogatory is vague AND over broad AND overly burdensome.
- "Defendant objects to this Interrogatory as ambiguous, vague, overly broad, unduly burdensome, and as seeking information which is irrelevant to the issues in this litigation. Based on the foregoing, Defendant respectfully declines to provide a response to this interrogatory."
- After making an objection, you may use the following language, signifying that your response is subject to the objection and it is not waived, even though a response to the requested interrogatory is provided.
- "Subject to and without waiving any of Defendant's general objections, Defendant responds as follows:"
- The reservation of right (directly below) should be used after responding to the interrogatories at the end of the document but before the certification.
- "Discovery in this case is incomplete. Defendant reserves the right to supplement, change, or modify these responses to Plaintiff’s Interrogatories at any time."
- The person responding to the interrogatories may also object to:
- Questions not likely to lead to discoverable information; and
- Questions designed to solicit a legal conclusion
Practice Tips
- Rule 33 requires that you copy the interrogatory and put the answer below, however, the answer alone may also be acceptable.
- When you are drafting a Rule 37 Motion to Compel Answers to Interrogatories which you propounded, you should attach the interrogatory at issue and the other party's answer. This will result in the judge not needing to shuffle between documents, which will create 1) efficiency and 2) a happier judge (we hope).