STATE COURT DISCOVERY – INTERROGATORIES

(Alaska Superior Court)

[// GUIDANCE: This template is drafted for use in ordinary civil actions pending in the Alaska Superior Court. It is designed to comply with the Alaska Rules of Civil Procedure, particularly Rules 26 and 33, as well as applicable privilege doctrine. Customize defined terms, factual content, and the specific interrogatories to fit the particulars of your case. Verify all rule citations and time-period calculations against the most current version of the Alaska Rules and any applicable Standing Orders before serving.]

TABLE OF CONTENTS

1. Caption & Document Header
2. Preliminary Statement
3. Definitions
4. General Instructions
5. Interrogatories (Nos. 1-[##])
6. Verification
7. Certificate of Service

1. CAPTION & DOCUMENT HEADER

IN THE SUPERIOR COURT FOR THE STATE OF ALASKA
AT [JUDICIAL DISTRICT / LOCATION]

____, )
)
Plaintiff, )
)
v. ) Case No. [CASE NO.]
)
____, ) [PLAINTIFF’S / DEFENDANT’S]
) FIRST SET OF INTERROGATORIES
Defendant. ) TO [OPPOSING PARTY]
________ )
Effective Date of Service: [DATE]

2. PRELIMINARY STATEMENT

Pursuant to Alaska Rules of Civil Procedure 26 and 33, [PARTY PROPONENT] (“Propounding Party”) hereby serves the following Interrogatories upon [OPPOSING PARTY] (“Responding Party”). These Interrogatories are continuing in nature, and the Responding Party must supplement or amend its answers in accordance with Rule 26(e).

3. DEFINITIONS

For purposes of these Interrogatories:

1. “Action” means the above-captioned lawsuit.
2. “Communication” means the transmittal of information in any form.
3. “Document” is synonymous with the broadest meaning permitted under the Alaska Rules of Civil Procedure and includes electronically stored information (“ESI”).
4. “Identify” or “state the identity of” means:
   a. For a natural person: full name, present or last known address, telephone number, and place of employment;
   b. For a business entity: full legal name, address of principal place of business, and the name and title of the individual(s) acting for the entity;
   c. For a document: title, date, author(s), addressee(s), type, and present custodian.
5. “Person” includes both natural persons and legal entities.
6. “You,” “Your,” or “Responding Party” means [OPPOSING PARTY] and all agents, representatives, attorneys, and anyone acting or purporting to act on its behalf.

[// GUIDANCE: Insert additional defined terms specific to the facts (e.g., “Accident,” “Property,” “Agreement”).]

4. GENERAL INSTRUCTIONS

A. Discovery Limits. Absent leave of court or written stipulation, the total number of interrogatories, including all discrete subparts, may not exceed the maximum allowed under the Alaska Rules of Civil Procedure.

B. Response Deadline. Written answers and any objections must be served within 30 days after service of these Interrogatories, subject to the additional three-day mailing rule where applicable.

C. Answering Under Oath. Each answer must be made under oath by the party, officer, or agent furnishing the information.

D. Form of Answers.
1. State each answer fully and separately, immediately following the corresponding Interrogatory.
2. If any Interrogatory is objected to, state the specific grounds for objection and answer the remainder to the extent the Interrogatory is not objectionable.

E. Privilege & Work-Product. If information is withheld on the basis of privilege or work-product immunity:
1. State the privilege claimed; and
2. Provide a privilege log sufficient to enable other parties to assess the claim without revealing the privileged information.

F. Continuing Duty. These Interrogatories are continuing. Promptly supplement any response that is incomplete or incorrect when made, or that becomes incomplete or incorrect in light of subsequently acquired information.

5. INTERROGATORIES

[// GUIDANCE: Delete, revise, or reorder the sample Interrogatories. Ensure the final count does not exceed the Alaska rule-based limit.]

1. Identify every person likely to have discoverable information that you may use to support your claims or defenses, and describe the subjects of that information.

2. State the factual basis for each denial of a material allegation in the Complaint and identify all documents supporting each stated basis.

3. Itemize and explain in detail each category of damages you claim in this Action, including the method of calculation and identification of all supporting documents.

4. Describe the substance of every oral communication between you and [OTHER PARTY] concerning the matters alleged in the Complaint, specifying the date, participants, and content.

5. Identify all insurance agreements under which any person carrying on an insurance business may be liable to satisfy part or all of a judgment against you in this Action or to indemnify or reimburse you for payments made to satisfy the judgment.

6. State the complete factual basis for each affirmative defense you have pleaded, identifying all witnesses and documents that support each defense.

7. If you contend that any party other than yourself caused or contributed to the damages alleged, identify such party and describe the factual and legal basis for that contention.

8. Describe all efforts undertaken to preserve evidence relevant to this Action, including ESI, and identify the person responsible for overseeing evidence preservation.

9. Identify all experts you have retained or specially employed to provide testimony in this Action, and for each provide: (a) subject matter of expected testimony; (b) the facts or opinions to which the expert is expected to testify; and (c) a summary of the grounds for each opinion.

10. State whether you have ever been a party to any prior litigation involving similar claims or defenses; if so, identify the court, case number, date filed, and disposition of each such action.

11-__[##]. [ADD ADDITIONAL INTERROGATORIES AS NEEDED]

6. VERIFICATION

I, _____, certify under penalty of perjury that I am the [TITLE/POSITION] of [RESPONDING PARTY] and that I have read the foregoing Answers to Interrogatories and know the contents thereof; that the same are true to my knowledge, information, and belief, except as to those matters stated upon information and belief, and as to those matters I believe them to be true.

Executed on this ___ day of __, 20, at ___, Alaska.

[NAME]
[Title / Relationship to Responding Party]

7. CERTIFICATE OF SERVICE

I certify that on __, 20_, a true and correct copy of the foregoing [PLAINTIFF’S / DEFENDANT’S] First Set of Interrogatories to [OPPOSING PARTY] was served on:

[Name & Address of Counsel of Record]
[Method of Service: ☐ U.S. Mail ☐ Hand Delivery ☐ Email (by agreement) ☐ E-Service]

[ATTORNEY NAME], [Alaska Bar No. ______]
Counsel for [PROPONENT]

[// GUIDANCE:
1. Double-check that the combined total of interrogatories and discrete subparts does not exceed Alaska’s rule-based cap (currently forty (40)); seek leave of court for additional interrogatories if necessary.
2. Adjust the response deadline where the parties stipulate to a different period or the court orders otherwise.
3. Ensure privilege logs comply with any standing orders or local rules.
4. Consider simultaneous requests for production where interrogatories solicit identification of documents.
5. Confirm signature block format complies with the Alaska Bar Rules and any local page-limit or formatting requirements of the assigned judge.]