How To Deal With An Overly-Burdensome Interrogatory


My wife served me a 60-page interrogatory with 133 questions and many subparts. I believe this is unreasonable as I am aware of objections to almost all of the questions.

Can I force them to reduce the number of questions based on burden and relevance to the case?

Philadelphia divorce attorney William Phelan
Philadelphia divorce attorney William Phelan


While I am not licensed to practice law in your state, I can give some general guidance on this issue.

Where I practice in the District of Columbia, there is a limitation of 40 interrogatories per lawsuit (unless you have permission of the court to send more).

On the other hand, in Pennsylvania (where I also practice), there is no limitation on interrogatories, and sometimes a party in litigation may take advantage of this lack of a cap.

Therefore, Pennsylvania rules and practice ask the parties to first attempt to work together, in good faith, to resolve any potential discovery problems. If these good faith efforts fail, a party may, upon the proper filing, attain protection from the court if it is found that the discovery tactics being used are, for example, abusive or over-burdensome.

Yet, what a Pennsylvania judge may find abusive or over-burdensome is a very fact-specific inquiry and the result may even vary from judge to judge.

Because your situation may be controlled strictly by state rules of evidence and seems to involve a great deal of subjectivity, I would strongly suggest you contact an attorney who handles family law matters in your jurisdiction.

Remember, I am unable to provide you with anything more than divorce tips for men, so please consult a domestic litigation attorney in your jurisdiction to obtain specific advice as to the laws in your state and how they impact your potential case.

To arrange an initial consultation to discuss divorce rights for men with a Cordell & Cordell attorney, including Pennsylvania divorce lawyer William J. Phelan, IV, contact Cordell & Cordell.

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Shawn Garrison is an Online Editor for Lexicon, focusing on subjects related to the legal services of customers, Cordell & Cordell and Cordell & Cordell UK. He has written countless pieces dealing with the unique child custody and divorce issues that men and fathers face. Through his work on,, and, Mr. Garrison has become an authority on the complexities of the legal experience and was a content creator for the YouTube series “Dad’s Divorce Live” and additional videos on both the Dad’s Divorce and Cordell & Cordell YouTube channels. Mr. Garrison has managed the sites of these customers, and fostered the creation of several of their features, including the Cordell & Cordell attorney and office pages, the Dad’s Divorce Newsletter, and the Cordell & Cordell newsletter.

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