Form Interrogatories - Employment

FORM INTERROGATORIES — EMPLOYMENT

IN THE [________________________________] COURT
[____] JUDICIAL DISTRICT / DIVISION
[________________________________] COUNTY, [____] (STATE)

PROPOUNDING PARTY INFORMATION

PRELIMINARY STATEMENT

Pursuant to Federal Rule of Civil Procedure 33 (or the applicable state procedural rule), the Propounding Party hereby requests that the Responding Party answer the following interrogatories separately, fully, and under oath within thirty (30) days of service, or within the time prescribed by applicable rules.

These interrogatories are continuing in nature. If the Responding Party obtains additional or different information after serving responses, supplemental answers must be provided promptly as required by Fed. R. Civ. P. 26(e).

Federal Practice Note: FRCP Rule 33(a)(1) limits a party to 25 interrogatories, including discrete subparts, absent stipulation or court order. The interrogatories below are organized by topic to allow practitioners to select the most relevant questions within the applicable limit. Where a jurisdiction imposes no limit on form interrogatories (e.g., California), additional questions may be propounded.

INSTRUCTIONS FOR ANSWERING

1. Oath Requirement. Each answer must be made under oath by the party to whom the interrogatories are directed, or by an officer or agent of a corporate party who shall furnish all information available to the party. See Fed. R. Civ. P. 33(b)(1)(A)-(B).

2. Full and Complete Answers. Each interrogatory must be answered separately and fully in writing. If information is not available, state that fact and describe what efforts were made to obtain the information. See Fed. R. Civ. P. 33(b)(3).

3. Objections. If you object to any interrogatory, state the objection with specificity and answer the non-objectionable portion. Any ground not stated in a timely objection is waived unless the court, for good cause, excuses the failure. See Fed. R. Civ. P. 33(b)(4).

4. Business Records Option. Where the answer may be derived from business records and the burden of deriving the answer is substantially the same for either party, you may specify the records from which the answer can be derived and afford the propounding party reasonable opportunity to examine them. See Fed. R. Civ. P. 33(d).

5. Identification of Persons. When asked to "identify" a person, provide the person's full name, last known address, telephone number, email address, current or last known employer, and job title.

6. Identification of Documents. When asked to "identify" a document, provide the document's title, date, author(s), recipient(s), a brief description of its contents, and its current location or custodian.

7. Supplementation Duty. Responses must be supplemented in a timely manner if the Responding Party learns that a response is incomplete or incorrect in some material respect, and if the additional or corrective information has not otherwise been made known to the other parties. See Fed. R. Civ. P. 26(e)(1).

8. Privilege Log. If any interrogatory is not fully answered based on a claim of privilege or work product protection, identify the information withheld, the privilege claimed, and the factual basis sufficient to evaluate the claim, as required by Fed. R. Civ. P. 26(b)(5).

DEFINITIONS

As used in these interrogatories, the following terms have the meanings set forth below:

1. "PLAINTIFF" means [________________________________], including any agents, employees, or representatives acting on Plaintiff's behalf.

2. "DEFENDANT" means [________________________________], including all parent, subsidiary, and affiliated companies, and all current and former officers, directors, managers, supervisors, agents, employees, attorneys, and representatives.

3. "YOU" or "YOUR" refers to the Responding Party and includes all persons or entities acting on the Responding Party's behalf.

4. "DOCUMENT" has the broadest meaning permitted under Fed. R. Civ. P. 34(a) and includes all writings, drawings, graphs, charts, photographs, sound recordings, images, electronically stored information (ESI), and other data compilations stored in any medium from which information can be obtained, translated if necessary.

5. "COMMUNICATION" means any oral, written, or electronic transmission of information, including but not limited to letters, memoranda, emails, text messages, instant messages, Slack or Teams messages, voicemails, social media posts or messages, and any other form of correspondence or exchange of information.

6. "IDENTIFY" means, with respect to a natural person: provide the person's full name, last known home and business addresses, telephone numbers, email addresses, job title, and employer. With respect to a document: provide the date, author, recipients, type of document, subject matter, and present custodian. With respect to a communication: provide the date, participants, method of communication, and substance.

7. "ADVERSE ACTION" means any termination, demotion, suspension, reduction in pay or benefits, failure to promote, failure to hire, transfer, reassignment, negative performance evaluation, written warning, disciplinary action, constructive discharge, or any other action that materially affects the terms, conditions, or privileges of employment.

8. "PROTECTED ACTIVITY" means any complaint, report, charge, lawsuit, testimony, refusal to participate in unlawful activity, request for accommodation, request for FMLA leave, or other activity protected by federal, state, or local anti-discrimination, anti-retaliation, or whistleblower statutes.

9. "COMPARATOR" means any person who held the same or similar position, had the same or similar job duties, worked under the same supervisor, or was otherwise similarly situated to the Plaintiff but who is outside the Plaintiff's protected class.

10. "RELEVANT TIME PERIOD" means the period from [__/__/____] through the present, unless a different time period is specified in an individual interrogatory.

11. "POLICY" means any written or unwritten rule, regulation, procedure, guideline, practice, standard, handbook provision, or custom of the Defendant.

12. "SUPERVISOR" means any person who had authority to hire, fire, promote, demote, discipline, assign work to, evaluate, or make recommendations concerning the Plaintiff.

13. "INVESTIGATION" means any inquiry, review, audit, examination, or proceeding conducted by or on behalf of the Defendant relating to complaints, reports, or allegations involving the Plaintiff or the Plaintiff's claims.

14. "CHARGE" means any charge of discrimination, complaint, or other filing made with the Equal Employment Opportunity Commission (EEOC), a state or local fair employment practices agency, or any other governmental body.

15. "BENEFITS" means all forms of compensation and benefits including but not limited to salary, wages, bonuses, commissions, stock options, equity awards, health insurance, retirement plan contributions, paid time off, severance, and any other perquisites of employment.

16. "ESI" means electronically stored information as defined by Fed. R. Civ. P. 34(a)(1)(A), including emails, text messages, instant messages, social media content, databases, spreadsheets, metadata, and data stored in cloud-based systems.

INTERROGATORIES

PART A: PARTIES AND BACKGROUND

INTERROGATORY NO. 1: State the full legal name, any former or trade names, state of incorporation or organization, principal place of business, and registered agent for each Defendant entity.

INTERROGATORY NO. 2: Identify each person who participated in preparing or supplying information for the answers to these interrogatories, including each person's name, title, and the interrogatories for which that person provided information.

INTERROGATORY NO. 3: Identify all persons who YOU contend have knowledge of the facts underlying the claims or defenses in this action, and for each, state the subject matter of their knowledge.

INTERROGATORY NO. 4: Identify all expert witnesses YOU expect to call at trial, and for each, state: (a) their qualifications; (b) the subject matter of their expected testimony; (c) the substance of the opinions they are expected to express; and (d) the basis and reasons for each opinion.

PART B: EMPLOYMENT HISTORY AND POSITION

INTERROGATORY NO. 5: Describe in detail the Plaintiff's employment history with the Defendant, including: (a) date of hire; (b) each position held and dates in each position; (c) job title and duties for each position; (d) department or division; (e) work location(s); (f) compensation (salary, hourly rate, bonuses, commissions) for each position; and (g) date and circumstances of separation.

INTERROGATORY NO. 6: Identify each person who directly or indirectly supervised the Plaintiff during the Plaintiff's employment, including dates of supervision and job title.

INTERROGATORY NO. 7: Identify each person who reported to the Plaintiff during the Plaintiff's employment, including dates and job titles.

INTERROGATORY NO. 8: Describe in detail the qualifications, experience, education, and credentials required for each position held by the Plaintiff, including any job descriptions in effect during the Plaintiff's employment.

INTERROGATORY NO. 9: Describe in detail all performance evaluations, reviews, or assessments of the Plaintiff during the Plaintiff's employment, including: (a) dates; (b) the evaluator(s); (c) the ratings or scores given; and (d) a summary of the substance of each evaluation.

PART C: HIRING, PROMOTION, AND COMPENSATION

INTERROGATORY NO. 10: Describe the process by which the Plaintiff was hired, including: (a) who made the hiring decision; (b) what criteria were used; (c) who else was considered; and (d) the basis for selecting the Plaintiff.

INTERROGATORY NO. 11: For each promotion, raise, or bonus the Plaintiff received during employment, identify: (a) the date; (b) the nature of the action; (c) the decision-maker(s); and (d) the criteria or reasons for the action.

INTERROGATORY NO. 12: For each promotion, raise, bonus, or other employment benefit the Plaintiff sought but did not receive, identify: (a) the date and nature of the request or candidacy; (b) the decision-maker(s); (c) the person(s) selected instead; (d) the qualifications of the person selected; and (e) the stated reason for not selecting the Plaintiff.

INTERROGATORY NO. 13: Describe in detail all compensation paid to the Plaintiff during the Relevant Time Period, including base salary, overtime, bonuses, commissions, equity awards, and all benefits.

PART D: ADVERSE ACTIONS AND DISCIPLINE

INTERROGATORY NO. 14: Identify each adverse action taken against the Plaintiff during the Relevant Time Period, and for each, state: (a) the date; (b) the nature of the action; (c) the person(s) who made or recommended the action; (d) the stated reason(s) for the action; and (e) all documents relating to the action.

INTERROGATORY NO. 15: Describe in detail the circumstances of the Plaintiff's termination, separation, or constructive discharge, including: (a) the date; (b) all person(s) involved in the decision; (c) the reason(s) given to the Plaintiff; (d) the actual reason(s); (e) all meetings or communications with the Plaintiff about the separation; and (f) whether any severance was offered.

INTERROGATORY NO. 16: Identify all written warnings, performance improvement plans (PIPs), counseling memoranda, or other disciplinary actions issued to the Plaintiff, including: (a) the date; (b) the issuing person; (c) the stated basis; and (d) the Plaintiff's response, if any.

INTERROGATORY NO. 17: For each adverse action identified in your response to Interrogatory No. 14, identify all persons who were consulted, advised, or informed before the action was taken.

INTERROGATORY NO. 18: State whether the Plaintiff's position was filled after the Plaintiff's separation, and if so, identify the person who filled the position, that person's date of hire or promotion, qualifications, protected class status (to the extent known), and current compensation.

PART E: DISCRIMINATION AND HARASSMENT

INTERROGATORY NO. 19: Describe in detail each act of discrimination, harassment, or hostile work environment that the Plaintiff alleges, including: (a) dates; (b) the person(s) who committed the act; (c) the nature and circumstances of the act; (d) witnesses to the act; and (e) the protected characteristic at issue.

INTERROGATORY NO. 20: Identify all comparators — persons similarly situated to the Plaintiff who were not in the Plaintiff's protected class — and for each, state: (a) name and job title; (b) supervisor; (c) job performance history; (d) disciplinary history; and (e) how the person was treated differently from the Plaintiff.

INTERROGATORY NO. 21: State whether any person made comments, remarks, jokes, or statements relating to the Plaintiff's [race/color/sex/gender/national origin/religion/age/disability/other protected characteristic] during the Relevant Time Period, and for each such statement, identify: (a) the speaker; (b) the date and location; (c) the substance of the statement; and (d) all witnesses.

INTERROGATORY NO. 22: Describe in detail any pattern or practice of discrimination by the Defendant against persons in the Plaintiff's protected class, including any statistical evidence, prior complaints, or other evidence of such a pattern.

INTERROGATORY NO. 23: Identify all complaints of discrimination, harassment, or retaliation made by any person against the same individual(s) accused by the Plaintiff, including: (a) the date of the complaint; (b) the complainant's name; (c) the nature of the complaint; and (d) the outcome.

PART F: RETALIATION

INTERROGATORY NO. 24: Identify all protected activities in which the Plaintiff engaged during the Relevant Time Period, including: (a) the date; (b) the nature of the activity; (c) the person(s) to whom it was directed; and (d) any response by the Defendant.

INTERROGATORY NO. 25: Describe the temporal relationship between each protected activity identified in your response to Interrogatory No. 24 and each adverse action identified in your response to Interrogatory No. 14.

INTERROGATORY NO. 26: Identify all persons who knew of the Plaintiff's protected activity before any adverse action was taken, and describe how and when they learned of the protected activity.

INTERROGATORY NO. 27: State whether the Defendant has taken adverse action against any other employee who engaged in similar protected activity during the past five (5) years, and if so, provide details.

PART G: COMPLAINTS AND INVESTIGATIONS

INTERROGATORY NO. 28: Describe in detail each complaint, report, or grievance the Plaintiff made to the Defendant, whether oral or written, including: (a) the date; (b) the person(s) to whom the complaint was made; (c) the substance of the complaint; (d) the method (verbal, written, hotline, etc.); and (e) the Defendant's response.

INTERROGATORY NO. 29: Describe in detail each investigation conducted by the Defendant in response to the Plaintiff's complaints, including: (a) who conducted the investigation; (b) the dates; (c) persons interviewed; (d) documents reviewed; (e) findings; and (f) corrective actions taken, if any.

INTERROGATORY NO. 30: State whether the Defendant retained any outside investigator, law firm, or consultant to investigate the Plaintiff's complaints, and if so, identify the entity, the scope of its engagement, and its findings.

INTERROGATORY NO. 31: Identify all communications between the Defendant and any government agency (including the EEOC, state or local fair employment agency, Department of Labor, or OSHA) regarding the Plaintiff or the Plaintiff's claims.

PART H: POLICIES AND PROCEDURES

INTERROGATORY NO. 32: Identify each employee handbook, policy manual, or code of conduct in effect during the Plaintiff's employment, including the effective dates and any amendments.

INTERROGATORY NO. 33: Describe in detail the Defendant's policies and procedures for: (a) reporting and investigating complaints of discrimination, harassment, and retaliation; (b) progressive discipline; (c) termination; and (d) performance evaluation.

INTERROGATORY NO. 34: Describe in detail the Defendant's anti-discrimination and anti-harassment training programs during the Relevant Time Period, including: (a) the frequency; (b) the content; (c) who attended; (d) who conducted the training; and (e) whether the Plaintiff's accused harasser or discriminating official attended.

INTERROGATORY NO. 35: Describe the Defendant's reasonable accommodation process, including the interactive process under the ADA, and identify all accommodation requests made by the Plaintiff and the Defendant's response to each.

INTERROGATORY NO. 36: Describe the Defendant's policies regarding employee records retention, document preservation, and litigation holds, and state what steps were taken to preserve relevant documents and ESI after the Plaintiff's complaint or charge was filed.

PART I: WAGE AND HOUR (FLSA / STATE LAW)

INTERROGATORY NO. 37: State the Plaintiff's classification as exempt or non-exempt under the FLSA and applicable state law during the Relevant Time Period, and describe the basis for that classification.

INTERROGATORY NO. 38: Describe in detail all hours worked by the Plaintiff during the Relevant Time Period, including regular hours, overtime hours, and any meal or rest period violations.

INTERROGATORY NO. 39: Identify all methods used to record the Plaintiff's work hours during the Relevant Time Period, including timekeeping systems, electronic badge records, and manual logs.

INTERROGATORY NO. 40: Describe any changes to the Plaintiff's compensation, work schedule, or job duties during the Relevant Time Period, and the reason for each change.

INTERROGATORY NO. 41: Identify all deductions made from the Plaintiff's pay during the Relevant Time Period, and the basis for each deduction.

PART J: FMLA AND LEAVE

INTERROGATORY NO. 42: Describe in detail each request for leave made by the Plaintiff during the Relevant Time Period, including: (a) the date of the request; (b) the type of leave requested; (c) the person(s) to whom the request was made; (d) the dates of leave taken; and (e) whether the leave was approved or denied and the reason.

INTERROGATORY NO. 43: State whether the Defendant designated any of the Plaintiff's leave as FMLA-qualifying leave, and if so, identify: (a) the dates; (b) the medical certification, if any; and (c) whether the Plaintiff was restored to the same or equivalent position upon return.

INTERROGATORY NO. 44: Identify all other employees who requested or took similar leave during the Relevant Time Period, and describe how each was treated.

PART K: BENEFITS

INTERROGATORY NO. 45: Describe in detail all employee benefits available to the Plaintiff during the Relevant Time Period, including health insurance, retirement plans (401(k), pension), stock options, equity awards, life insurance, disability insurance, and any other benefits.

INTERROGATORY NO. 46: State whether any of the Plaintiff's benefits were modified, reduced, or terminated during the Relevant Time Period, and if so, describe the change and the reason.

INTERROGATORY NO. 47: Describe the COBRA or continuation coverage notice provided to the Plaintiff after separation, including dates and terms.

PART L: DAMAGES AND MITIGATION

INTERROGATORY NO. 48: Describe in detail all damages claimed by the Plaintiff, including but not limited to: (a) back pay; (b) front pay; (c) lost benefits; (d) emotional distress; (e) reputational harm; (f) out-of-pocket expenses; (g) attorneys' fees; and (h) punitive damages.

INTERROGATORY NO. 49: Describe in detail all efforts by the Plaintiff to mitigate damages, including: (a) all positions applied for since separation, with dates, employer names, positions, and outcomes; (b) all employment obtained since separation, with dates, employer names, positions, and compensation; (c) all contacts with employment agencies or recruiters; and (d) any education or training undertaken.

INTERROGATORY NO. 50: Identify all income, compensation, or benefits received by the Plaintiff from any source since separation from the Defendant, including unemployment insurance, disability benefits, and earnings from any employment.

INTERROGATORY NO. 51: Identify all healthcare providers, counselors, therapists, or other professionals from whom the Plaintiff has received treatment for emotional distress, mental health conditions, or physical conditions allegedly caused or exacerbated by the Defendant's conduct, including: (a) the provider's name and address; (b) dates of treatment; and (c) the nature of treatment.

INTERROGATORY NO. 52: State the total amount of damages claimed by the Plaintiff in each category (e.g., back pay, front pay, emotional distress, punitive damages), and describe the method of calculation for each.

PART M: WITNESSES AND EVIDENCE

INTERROGATORY NO. 53: Identify all persons YOU expect to call as witnesses at trial, and for each, state the subject matter of their expected testimony.

INTERROGATORY NO. 54: Identify all documents, recordings, photographs, or other tangible evidence YOU intend to introduce at trial.

INTERROGATORY NO. 55: Identify all statements, whether written or recorded, obtained from any person regarding the facts of this case, and state the date, the person who gave the statement, and the person who took or obtained the statement.

PART N: PRIOR LITIGATION AND COMPLAINTS

INTERROGATORY NO. 56: Identify all lawsuits, charges, complaints, or grievances filed by or against the Plaintiff involving employment matters within the past ten (10) years, including: (a) the forum; (b) the case number; (c) the parties; (d) the nature of the claims; and (e) the outcome.

INTERROGATORY NO. 57: Identify all lawsuits, charges, complaints, or administrative proceedings alleging discrimination, harassment, or retaliation against the Defendant within the past five (5) years, including: (a) the complainant; (b) the forum; (c) the nature of the claims; and (d) the outcome.

PART O: INSURANCE AND INDEMNIFICATION

INTERROGATORY NO. 58: Identify all insurance policies that may provide coverage for the claims asserted in this action, including the insurer, policy number, coverage limits, and whether coverage has been accepted or denied.

INTERROGATORY NO. 59: Identify all indemnification agreements between the Defendant and any individual defendant or decision-maker relevant to this action.

PART P: ELECTRONIC RECORDS AND COMMUNICATIONS

INTERROGATORY NO. 60: Describe all electronic communications platforms used by the Defendant during the Relevant Time Period (including email, instant messaging, Slack, Microsoft Teams, and text messaging), and identify the custodian(s) responsible for maintaining records of such communications.

INTERROGATORY NO. 61: Describe the Defendant's document retention and destruction policies for electronic records, including backup procedures and any litigation hold implemented in connection with this matter.

INTERROGATORY NO. 62: Identify all social media accounts maintained by any person relevant to this action that contain communications or postings related to the Plaintiff, the Plaintiff's employment, or the events at issue.

PART Q: AFFIRMATIVE DEFENSES AND LEGAL CONTENTIONS

INTERROGATORY NO. 63: If YOU contend that Plaintiff failed to exhaust administrative remedies, state in detail the factual and legal basis for that contention.

INTERROGATORY NO. 64: If YOU contend that any of Plaintiff's claims are barred by any statute of limitations, identify the statute, the applicable limitations period, and the facts supporting that defense.

INTERROGATORY NO. 65: If YOU contend that Plaintiff failed to mitigate damages, describe in detail the basis for that contention, including the specific steps YOU contend Plaintiff should have taken.

INTERROGATORY NO. 66: If YOU contend that the adverse action taken against Plaintiff was motivated by legitimate, non-discriminatory, and non-retaliatory reasons, identify each such reason and all facts supporting that contention.

INTERROGATORY NO. 67: If YOU contend that the same adverse action would have been taken against Plaintiff absent the protected activity or protected characteristic, describe in detail the factual basis for that contention.

INTERROGATORY NO. 68: If YOU assert the Faragher-Ellerth affirmative defense, state: (a) the specific unreasonable failure by the Plaintiff to take advantage of preventive or corrective opportunities; and (b) all preventive and corrective opportunities available to Plaintiff.

PART R: SETTLEMENT AND REMEDIAL MEASURES

INTERROGATORY NO. 69: Identify all settlement demands or offers exchanged between the parties in this action, including the date, amount, and terms of each.

INTERROGATORY NO. 70: Describe all remedial measures taken by the Defendant in response to the events giving rise to this action, including any policy changes, training, personnel actions, or structural changes.

PRACTICE NOTES FOR ATTORNEYS

Federal Court Interrogatory Strategy

• 25-Interrogatory Limit (FRCP 33(a)(1)): Select the most relevant interrogatories from each Part. Prioritize interrogatories that are difficult to obtain through document requests or depositions — such as the identities of decision-makers, the reasons for adverse actions, and the factual bases for affirmative defenses.
• Subparts: Courts vary on what constitutes a "discrete subpart." Generally, logically related sub-questions within a single interrogatory are treated as one interrogatory. Unrelated sub-questions may each count separately. See Trevino v. ACB American, Inc., 164 F.R.D. 517 (E.D. La. 1995).
• Contention Interrogatories: Part Q contains contention interrogatories that are generally permissible but may be deferred by the court until later in discovery. Consider timing. See Fed. R. Civ. P. 33(a)(2).
• Use with Other Discovery: Interrogatories are most effective when paired with document requests and depositions. Use interrogatory responses to identify custodians and topics for depositions.

Proportionality Considerations

Under Fed. R. Civ. P. 26(b)(1), discovery must be proportional to the needs of the case, considering:
- The importance of the issues at stake
- The amount in controversy
- The parties' relative access to relevant information
- The parties' resources
- The importance of the discovery in resolving the issues
- Whether the burden or expense outweighs its likely benefit

STATE-SPECIFIC PRACTICE NOTES

California

• Form Interrogatories: California Judicial Council Form Interrogatories (DISC-001) have no numeric limit. Use Judicial Council Form DISC-001, Employment Law Set, for standard employment questions. See Cal. Code Civ. Proc. (CCP) Section 2030.310.
• Special Interrogatories: Limited to 35 per party without a supporting declaration. A declaration of necessity under CCP Section 2030.050 is required to exceed 35. See CCP Section 2030.030.
• Response Time: 30 days from service; 35 days if served by mail within California. See CCP Section 2030.260.
• FEHA Claims: The California Fair Employment and Housing Act (Gov. Code Section 12940 et seq.) provides broader protections than federal law, including no cap on compensatory damages.

Texas

• Interrogatory Limits: Level 2 discovery (default): 25 interrogatories, excluding those asking a party to identify or authenticate documents. Level 1 (expedited): 15 interrogatories. See Tex. R. Civ. P. 190.2, 190.3, 197.
• Response Time: 30 days from service. See Tex. R. Civ. P. 197.2.
• Subparts: Each discrete subpart counts as a separate interrogatory. See Tex. R. Civ. P. 190.3(b)(3).
• TCHRA Claims: Texas Commission on Human Rights Act (Tex. Lab. Code Ch. 21) mirrors Title VII with a 180-day charge filing deadline.

Florida

• Interrogatory Limits: 30 interrogatories, including all subparts, per party without leave of court. See Fla. R. Civ. P. 1.340(a).
• Response Time: 30 days from service; 45 days for a defendant served before the answer is due. See Fla. R. Civ. P. 1.340(a).
• 2025 Amendments: Recent amendments to the Florida Rules of Civil Procedure affect discovery procedures. Verify current rules before filing.
• FCRA Claims: Florida Civil Rights Act (Fla. Stat. Section 760.01 et seq.) is construed consistently with federal law.

New York

• Interrogatories: CPLR Section 3130 permits interrogatories after commencement of the action, but a party may not serve both interrogatories and demand a bill of particulars from the same party (except in matrimonial actions). See CPLR Section 3130.
• Response Time: 20 days from service. See CPLR Section 3133.
• Limitation: In personal injury, property damage, or wrongful death actions based on negligence, a party cannot serve both interrogatories and take a deposition of the same party without leave of court. See CPLR Section 3130.
• NYSHRL/NYCHRL Claims: New York State Human Rights Law (N.Y. Exec. Law Section 296) and New York City Human Rights Law (N.Y.C. Admin. Code Section 8-107) provide broader protections than federal law, including individual liability for supervisors.

VERIFICATION

I, [________________________________], declare under penalty of perjury under the laws of [________________________________] (state) and of the United States that the foregoing answers are true and correct to the best of my knowledge, information, and belief.

☐ Responding Party is an individual
☐ Responding Party is a corporate officer or authorized agent

Executed on: [__/__/____]

At: [________________________________] (City, State)

_______________________________________________
[RESPONDING PARTY NAME — Printed]

_______________________________________________
[SIGNATURE]

Title (if corporate representative): [________________________________]

CERTIFICATE OF SERVICE

I, [________________________________], hereby certify that on [__/__/____], I served the foregoing FORM INTERROGATORIES — EMPLOYMENT upon all counsel of record by the following method:

☐ Electronic filing (ECF/e-filing system)
☐ Email to: [________________________________]
☐ U.S. Mail, first class, postage prepaid
☐ Hand delivery
☐ Overnight courier

Served upon:

[________________________________]
[________________________________]
[________________________________]
[________________________________]
[________________________________]

_______________________________________________
[ATTORNEY NAME]
[FIRM NAME]
[ADDRESS]
[CITY, STATE ZIP]
[PHONE]
[EMAIL]
[BAR NUMBER]
Attorney for [________________________________]

SOURCES AND REFERENCES

• Federal Rules of Civil Procedure, Rules 26, 33 — https://www.law.cornell.edu/rules/frcp
• Title VII of the Civil Rights Act of 1964, 42 U.S.C. Section 2000e et seq.
• Americans with Disabilities Act (ADA), 42 U.S.C. Section 12101 et seq.
• Age Discrimination in Employment Act (ADEA), 29 U.S.C. Section 621 et seq.
• Family and Medical Leave Act (FMLA), 29 U.S.C. Section 2601 et seq.
• Fair Labor Standards Act (FLSA), 29 U.S.C. Section 201 et seq.
• California Code of Civil Procedure, Sections 2030.010-2030.410
• Texas Rules of Civil Procedure, Rules 190, 197
• Florida Rules of Civil Procedure, Rule 1.340
• New York CPLR, Sections 3130-3133

Disclaimer: This template is provided for informational purposes only and does not constitute legal advice. An attorney licensed in the relevant jurisdiction must review and customize this document before use. Laws and procedural rules vary by jurisdiction and change frequently. Use of this template does not create an attorney-client relationship.

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