One of the odder procedural twists is that Minnesota has standard interrogatories in medical malpractice cases. Minn. Stat. § 604.11. This limitation goes both ways and applies to both plaintiffs and defendants. Id. For plaintiffs seeking information from medical defendants, Minnesota allows the service of 27 standard interrogatories and ten additional nonuniform interrogatories. Going the other way, the statute includes 15 uniform interrogatories to an injured plaintiff and 27 uniform interrogatories to the trustee in a wrongful death case.
The uniform interrogatories are explicitly spelled out in the statute and do not allow for much customization. In my view, the process does not work because even though the legislature spelled out exactly the questions plaintiffs can ask, the interrogatories still draw objections – including that they are “vague,” “unduly burdensome,” and “overly broad.” Such objections are improper and parties should answer the statutorily-defined interrogatories without such objections attacking their form. Interestingly, some of those same responses including objections as to form will include an admonition that you have exceeded your ten nonuniform interrogatory limit. Practitioners should be aware of these uniform interrogatories and incorporate them accordingly into their discovery practice.