Memorandum Opinion and Order

On February 16, 2005, Massachusetts Mutual (“Mass Mutual”) filed a Motion to Compel seeking Plaintiff’s  answers to certain of its interrogatories and requests for production of documents. (Docket # 34.)  Mass Mutual had served Plaintiff, LaDonna Saria (“Saria”), with 28 interrogatories, many of which contained subparts.  The number of interrogatories, including these subparts, exceeded the limit (50) which the parties had agreed upon.  Saria initially lodged a numerousity objection to all interrogatories, and did not answer any of them.  She later agreed to answer those interrogatories “to which [she] had no objection”, and apparently selected those to which she responded.  However, certain of Saria’s answers were simple references to other pleadings rather than responses crafted to answer the interrogatory. Saria raised relevancy and undue hardship objections to various interrogatories and requests as well.  Saria’s responses were neither verified nor signed.