§ Rule 4005 Written Interrogatories to a Party

Codes > Pennsylvania Rules of Civil Procedure > Depositions and > Rule 4005

Rule 4005. Written Interrogatories to a Party

    (a) Subject to the limitations provided by Rule 4011, any party may serve upon any other party written interrogatories to be answered by the party served or, if the party served is a public or private corporation or similar entity or a partnership or association, by any officer or agent, who shall furnish such information as is available to the party. Interrogatories may be served upon any party at the time of service of the original process or at any time thereafter. Interrogatories which are to be served prior to service of the complaint shall be limited to the purpose of preparing a complaint and shall contain a brief statement of the nature of the cause of action. Interrogatories shall be prepared in such fashion that sufficient space is provided immediately after each interrogatory or subsection thereof for insertion of the answer or objection.

        Note: Rule 440 requires the party serving interrogatories upon any other party to serve a copy upon every party to the action.

    Interrogatories that generally require the responding party to state the basis of particular claims, defenses or contentions made in pleadings or other documents should be used sparingly and, if used, should be designed to target claims, defenses or contentions that the propounding attorney reasonably suspects may be the proper subjects of early dismissal or resolution or, alternatively, to identify and to narrow the scope of claims, defenses and contentions made where the scope is unclear.

    See Rule 4003.8 governing pre-complaint discovery.

    (b) Rescinded Nov. 20, 1978, effective April 16, 1979.

        Note: The subject matter governed by former Rule 4005(b) has been transferred to Rule 4006(a).

    (c) Interrogatories may relate to any matters which can be inquired into under Rules 4003.1 through 4003.5 inclusive and the answers may be used to the same extent as provided in Rule 4020 for the use of the deposition of a party. Interrogatories may be served after a deposition has been taken, and a deposition may be taken after interrogatories have been answered, but the court, on motion of the party interrogated, may make such protective order as justice requires. The number of interrogatories or of sets of interrogatories to be served may be limited as justice requires to protect the party from unreasonable annoyance, embarrassment, oppression, burden or expense.