[UNITED STATES DISTRICT COURT]

[DISTRICT/DIVISION] OF [JURISDICTION]

[PLAINTIFF NAME],
  Plaintiff,

v. Civil Action No. [XX-XXXX]

[DEFENDANT NAME],
  Defendant.

PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT

[// GUIDANCE: Swap “Plaintiff”/“Defendant” designations as appropriate.]

Effective Date: [MM/DD/YYYY]

Pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure (“Fed. R. Civ. P.”), [PROPONENT PARTY NAME] (the “Propounding Party”) hereby serves the following interrogatories on [RESPONDING PARTY NAME] (the “Responding Party”). Responses must be served within thirty (30) days of service hereof, or within any other period ordered by the Court or stipulated to by the parties.

TABLE OF CONTENTS

1. Definitions
2. General Instructions
3. Interrogatories Nos. 1 – [25]
4. Verification
5. Certificate of Service

1. DEFINITIONS

Unless the context indicates otherwise, the following Definitions apply to every part of these interrogatories:

“Action” means the above-captioned lawsuit, including all claims, defenses, counterclaims, and third-party claims.
“Communication” means any transmission of information, whether oral, written, electronic, or otherwise, including but not limited to letters, emails, texts, chats, telephone calls, voicemails, meetings, and social-media posts.
“Document” has the broadest meaning permitted under Fed. R. Civ. P. 34(a), including ESI (electronically stored information).
“Identify” or “Identification” when used in reference to:
 (a) a natural person – state the person’s full name, present or last known address, telephone number, employer, and job title;
 (b) a corporation, partnership, or legal entity – state its full name, place of incorporation/organization, principal place of business, and the identity of a representative with knowledge of the subject matter;
 (c) a document – state its title, date, author(s), recipient(s), type (e.g., email, memo), and Bates number(s) or other identifying information.
“You,” “Your,” or “Responding Party” means [RESPONDING PARTY NAME], including all present and former parents, subsidiaries, affiliates, predecessors, successors, officers, directors, employees, agents, representatives, and attorneys.

[// GUIDANCE: Add or narrow definitions to fit the specific dispute.]

2. GENERAL INSTRUCTIONS

1. Rule 33 Compliance. Each answer must be made separately and fully, in writing, under oath. See Fed. R. Civ. P. 33(b)(3).
2. Duty to Supplement. The Responding Party must supplement or correct its answers in accordance with Fed. R. Civ. P. 26(e).
3. Scope & Construction. Terms shall be construed to bring within the scope of the interrogatories all information that might otherwise be construed to be outside their scope. The conjunctive “and” includes the disjunctive “or,” and vice versa.
4. Objections. For each interrogatory partially or wholly refused, state all grounds with specificity. If an interrogatory is objected to in part, answer the unobjectionable portion. Fed. R. Civ. P. 33(b)(4).
5. Privilege. If any information is withheld on the basis of privilege or work-product protection, provide a privilege log identifying the nature of the information withheld sufficient to comply with Fed. R. Civ. P. 26(b)(5).
6. Time Period. Unless otherwise specified, the relevant time period is [START DATE] through the present.
7. Numerosity. The Propounding Party reserves the right to serve additional interrogatories upon leave of court or stipulation should the numerical limits of Fed. R. Civ. P. 33(a)(1) be reached.

3. INTERROGATORIES

[// GUIDANCE: Tailor, rearrange, or delete interrogatories to align with case-specific claims/defenses and avoid exceeding the 25-interrogatory cap (including discrete subparts).]

Interrogatory No. 1

Identify each person who participated in answering these interrogatories, including counsel, and describe the information supplied by each individual.

Interrogatory No. 2

Describe in detail the factual bases for each affirmative defense asserted by You in this Action, including identification of all Documents and Communications supporting each factual contention.

Interrogatory No. 3

State the name, last known address, and telephone number of every person likely to have discoverable information that You may use to support Your claims or defenses, and for each, summarize the subject matter of that information. See Fed. R. Civ. P. 26(a)(1)(A)(i).

Interrogatory No. 4

Identify all insurance agreements under which any person carrying on an insurance business may be liable to satisfy part or all of a judgment in this Action or to indemnify or reimburse payments made to satisfy the judgment. Fed. R. Civ. P. 26(a)(1)(A)(iv).

Interrogatory No. 5

State the total amount of damages You contend You have sustained (or will sustain) as a result of the events alleged in the pleadings, and describe in detail the methodology and computations used to arrive at each category of damages.

Interrogatory No. 6

Identify every expert witness You have retained or specially employed to provide testimony in this Action and, for each, state (a) the subject matter on which the expert is expected to testify, (b) the facts and opinions to which the expert is expected to testify, and (c) a summary of the grounds for each opinion.

Interrogatory No. 7

Describe each Communication between You and any third party concerning the claims or defenses in this Action, including the date, participants, and subject matter of each Communication.

Interrogatory No. 8

Identify all Documents that You contend support Your contention that [INSERT CONTENTION – e.g., “the contract was terminated for cause”].

Interrogatory No. 9

For each statement or allegation in the Complaint that You deny, state the factual basis for the denial.

Interrogatory No. 10

State whether You contend that any third party is wholly or partially responsible for the damages alleged in this Action and, if so, identify such third party and describe in detail the basis for Your contention.

Interrogatory No. 11

Identify each person who was involved in negotiating, drafting, or approving the [RELEVANT AGREEMENT OR DOCUMENT] and describe that person’s role.

Interrogatory No. 12

Describe with particularity all steps You have taken to preserve Documents and ESI relevant to this Action, including the issuance of litigation hold notices.

Interrogatory No. 13

If You contend that venue is improper in this Court, state all facts supporting that contention and identify all Documents and Communications supporting same.

Interrogatory No. 14

Identify all facts, Documents, and Communications that support Your contention that You acted reasonably and in good faith with respect to [DISPUTED ACTION].

Interrogatory No. 15

Describe any remedial or corrective actions You have taken in response to the events giving rise to this Action, including the dates such actions were implemented and the individuals responsible.

[// GUIDANCE: Continue numbering up to “Interrogatory No. 25” as needed, ensuring each discrete subpart is counted toward the 25-interrogatory limit.]

4. VERIFICATION

I, [NAME OF RESPONDING PARTY REPRESENTATIVE], declare under penalty of perjury that I am duly authorized to make this Verification and that the foregoing Answers to Interrogatories are true and correct to the best of my knowledge, information, and belief.
28 U.S.C. § 1746.

Date: _____, 20__

Signature: _____
Name: _____
Title/Capacity: ________

5. CERTIFICATE OF SERVICE

I hereby certify that on this [DAY] day of [MONTH], 20[YY], I caused the foregoing Plaintiff’s First Set of Interrogatories to Defendant to be served upon all counsel of record via [E-SERVICE PLATFORM / E-MAIL / HAND DELIVERY / U.S. MAIL] pursuant to Fed. R. Civ. P. 5(b).

[ATTORNEY NAME], Esq.
[Law Firm Name]
[Bar No.]
[Address]
[Telephone]
[Email]

[// GUIDANCE: Confirm local rules for acceptable service methods and any mandated certificates or word-count certifications.]