FORM INTERROGATORIES - CONTRACT AND COMMERCIAL

Instructions

1. Answer each interrogatory separately and fully in writing under oath.
2. If you object, state the grounds and answer the non-objectionable portion.
3. Identify any documents supporting your responses.

Definitions

• "Agreement" means the contract(s) at issue, including amendments.
• "Communication" includes emails, texts, letters, calls, and meetings.
• "Document" includes electronically stored information.

Interrogatories

1. Identify the person(s) most knowledgeable about the Agreement and performance.
2. Describe how and when the Agreement was formed.
3. Identify all amendments, change orders, or modifications to the Agreement.
4. Describe your performance under the Agreement.
5. Describe the alleged breach by the other party.
6. Identify all communications concerning performance, disputes, or termination.
7. State the dates of any notices of default, cure, or termination.
8. Identify all damages you claim and how they were calculated.
9. Describe steps taken to mitigate damages.
10. Identify all third parties involved in performance or delivery.
11. Identify any warranties or representations relevant to the dispute.
12. Identify any insurance coverage applicable to the claims.
13. Identify any prior or related disputes between the parties.
14. State whether any arbitration or ADR clause applies and its terms.
15. Identify all documents supporting your defenses or counterclaims.

Verification

text
I declare under penalty of perjury that the foregoing answers are true and correct.

______________________________
[RESPONDING PARTY NAME]
Date: [DATE]