• February 1, 2019

For those of our readers who are unfamiliar with texting/Twitter acronyms/abbreviations, TIL = “Today I learned [about]….”

We recently encountered this objection to an interrogatory that we had not seen before:

[I]t is an impermissible “blockbuster” interrogatory which seeks to elicit every fact related to the action in one interrogatory. See Hilt v. SFC, Inc., 170 F.R.D. 182 (D. Kan. 1997) (“there comes at some point a reasonable limit against indiscriminately hurling interrogatories at every conceivable detail and fact which may relate to a case…. Indiscriminate use of blockbuster interrogatories, such as these, do not comport with the just, speedy, and inexpensive determination of the action. To require answers to them would more likely cause delay and unreasonable expense of time, energy, and perhaps money.”).

It is an odd objection in that it coins a phrase, “blockbuster interrogatory,” for an extraordinarily common and generic interrogatory (e.g., “Identify all the people with knowledge of the claims and defenses asserted in this case….”) and characterizes it as “impermissible,” which it is not. But it is a catchy phrase, no?

In our experience, whatever you call them, these so called “blockbuster interrogatories” are, as a practical matter, fairly useless. Such interrogatories are often objected to as “overbroad,” “burdensome,” and (by some) “unanswerable,” but maybe the rules will be amended to bar blockbuster interrogatories so they are actually “impermissible” in addition to being useless.


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