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In Massachusetts, a litigant served with pretrial interrogatories may object to some or all of the questions asked if any of the following conditions apply.

  1. The question is not relevant to the lawsuit;
  2. Answering the question would be unduly burdensome or oppressive to the responding party;
  3. The question seekings information that is protected by the work product doctrine or some other legal privilege.

In addition to these grounds for objection, a litigant does not need to answer an interrogatory question if it seeks information which the opposing party has equal access to.

According to the procedural rules,

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. 

Mass. R. Civ. P. 33(c).