Rule 4:8.Interrogatories to Parties.

Part Four: Pretrial Procedures, Dispositions and Production at Trial · Last amended 2024 · Last verified July 16, 2026

In one sentenceRule 4:8 lets any party serve up to 30 written interrogatories on another party — or on an officer or agent if the party is an organization — requiring answers under oath within 21 or 28 days, with an option to point to business records instead of writing out an answer.

Full Text of Rule 4:8

Text sizeJump to: (a) (b) (c) (d) (e) (f) (g)

(a) Availability; Procedures for Use. — 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 a partnership or association or governmental agency, by any officer or agent, who must furnish such information as is available to the party. Interrogatories may, without leave of court, be served upon the plaintiff after commencement of the action and upon any other party with or after service of the complaint upon that party.

(b) Form. — The party answering the interrogatories must restate each question, by photocopying it or otherwise, then insert the word "Answer" and immediately thereafter state the response to that question. The answering party must attach the necessary oath and certificate of service to the answers.

(1) Interrogatories and answers or objections thereto should not be filed unless the court directs such filing on its own initiative or upon the request of any party prior to or during the trial.

(2) When the propriety or sufficiency of any interrogatory, answer or objection, or the service thereof, is challenged, or any other issue concerning such discovery is presented to the court for decision, copies of the relevant items, including any applicable certificates of service, must be made available to the court by counsel.

(3) In an Electronically Filed Case, submission of interrogatories, answers, objections and certificates of service as provided in subdivisions (c)(1) and (c)(2) of this Rule may be made by filing an electronic or digitally imaged copy thereof, unless the court directs otherwise.

(d) Answers. — Each interrogatory must be answered separately and fully in writing under oath, except to the extent it is objected to, in which event the reasons for any objection must be stated with specificity. Any part of an interrogatory that is not objected to must be answered. The answers must be signed by the person making them, and the objections signed by the attorney making them. The party upon whom the interrogatories have been served must serve a copy of the answers, and objections if any, within 21 days after the service of the interrogatories, except that a defendant may serve answers or objections within 28 days after service of the complaint upon that defendant. The court may allow a shorter or longer time. The party submitting the interrogatories may move for an order under Rule 4:12(a) with respect to any objection to or other failure to answer an interrogatory.

(e) Scope; Use. — Interrogatories may relate to any matters which can be inquired into under Rule 4:1(b), and the answers may be used to the extent permitted by the rules of evidence and for the purposes of Rule 3:20. Only such interrogatories and the answers thereto as are offered in evidence will become a part of the record.

An interrogatory otherwise proper is not necessarily objectionable merely because an answer to the interrogatory involves an opinion or contention that relates to fact or the application of law to fact, but the court may order that such an interrogatory need not be answered until after designated discovery has been completed or until a pre-trial conference or other later time.

(f) Option to Produce Business Records. — Where the answer to an interrogatory may be derived or ascertained from the business records, including electronically stored information, of the party upon whom the interrogatory has been served or from an examination, audit or inspection of such business records, or from a compilation, abstract or summary based thereon, and the burden of deriving or ascertaining the answer is substantially the same for the party serving the interrogatory as for the party served, it is a sufficient answer to such interrogatory to specify the records from which the answer may be derived or ascertained and to afford to the party serving the interrogatory reasonable opportunity to examine, audit or inspect such records and to make copies, compilations, abstracts or summaries. A specification must be in sufficient detail to permit the interrogating party to locate and to identify, as readily as can the party served, the records from which the answer may be ascertained. A specification of electronically stored information may be made under this Rule if the information will be made available in a reasonably usable form or forms.

(g) Limitation on Interrogatories. — No party may serve upon any other party, at any one time or cumulatively, more than thirty written interrogatories, including all parts and sub-parts without leave of court for good cause shown.

End

Plain-English Summary

Rule 4:8 governs written interrogatories, the question-and-answer counterpart to a deposition. Any party may serve them on any other party without leave of court, once the action has started; if the party served is a corporation, partnership, or agency, an officer or agent must supply whatever information is available to it. The answering party restates each question, labels the response “Answer,” and attaches the required oath and certificate of service.

Each interrogatory must be answered separately, fully, and under oath unless it is objected to — and any objection must state its reasons with specificity, while any part not objected to still gets answered. Responses are due within 21 days of service, or 28 days for a defendant answering after the complaint, though the court can shorten or lengthen that window. Interrogatories reach anything discoverable under Rule 4:1(b), and an interrogatory is not objectionable merely because it calls for an opinion or a contention involving the application of law to fact — though the court may put off answering such a question until later in the case. Where the answer can be pulled from business records just as easily by the requesting party as by the party served, Rule 4:8(f) lets the responding party point to the records instead of writing out the answer, as long as it identifies them specifically enough to be found.

Interrogatories and their answers are not filed with the court unless the court directs it or a dispute requires them, though copies must be made available to the court whenever their sufficiency is challenged. No party may serve more than 30 interrogatories, counting every part and subpart, without the court’s leave on a showing of good cause.

Frequently Asked Questions

How many interrogatories can a party serve in a Virginia civil case?

No more than 30, counting all parts and subparts, without the court’s leave for good cause (Rule 4:8(g)).

How long do you have to answer interrogatories in Virginia?

21 days after service, or 28 days for a defendant answering after being served with the complaint, unless the court sets a different time (Rule 4:8(d)).

Can you object to part of an interrogatory and answer the rest?

Yes. Rule 4:8(d) requires answering any part not objected to, while stating the reasons for objecting to the rest with specificity.

Can you answer an interrogatory by pointing to your business records instead of writing out the answer?

Yes, if the burden of finding the answer in those records is about the same for both sides. Rule 4:8(f) lets the responding party specify the records instead, in enough detail for the requesting party to locate them.

Do interrogatories get filed with the court in Virginia?

Not routinely. Rule 4:8(c) keeps them out of the court file unless the court directs otherwise or a party requests filing before or during trial.

Amendment History

Last amended by Order dated November 21, 2023; effective January 20, 2024.

Source & verification. Rule text and amendment history are reproduced verbatim from the Rules of Supreme Court of Virginia, published by the Supreme Court of Virginia. Last verified July 16, 2026. · Official source

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