I am a pro se advocate bringing my ex-wife (Plaintiff) back to court for a variety of issues. She is not adhering to the current court order and she will not communicate with me, at the same time she has coerced my teenage daughters to ignore me and my efforts for visitation. I am filing motions for contempt but I also think I need to file a Motion to Compel (information awarded to me but being withheld by her). Do I send to her the interrogatories prior to filing the Motion to Compel or do I send them to her, file and time the court date with her response time and she will bering the answers to Court (or not)…either way there would be a Motion to Compel on the docket for what ever response she delivers. Is there a limit on the number of questions? If the Court agrees that she has not adequately replied and grants a Motion to Compel, is this not a clear ticket for a Contempt of Court?


I’m not sure how the interrogatories relate to the motion to compel. Usually, you send interrogatories for answer, and when you do not receive the answers, you file a motion for compel the answers. You cannot time the motion with the answers as it is possible for the other party to obtain an extension to answer. You cannot ask more than 50 interrogatories, but you have to be aware that subparts may be considered individual questions.


Do I have to file the Interrogatories with the Clerk prior to sending them to the Plaintiff?


No, you do not have file the interrogatories with the court.