Alaska State Court Discovery Interrogatories

ALASKA STATE COURT DISCOVERY INTERROGATORIES

IN THE SUPERIOR COURT FOR THE STATE OF ALASKA

[________________________________] JUDICIAL DISTRICT AT [________________________________]

[________________________________],

Plaintiff,

v.

Case No.: [________________________________]

[________________________________],

Defendant.

[PLAINTIFF'S / DEFENDANT'S] FIRST SET OF INTERROGATORIES TO [OPPOSING PARTY]

ATTORNEY INFORMATION

TABLE OF CONTENTS

1. Introductory Statement and Authority
2. Definitions
3. Instructions
4. General Interrogatories (Nos. 1-18)
5. Case-Specific Interrogatories
6. Verification / Oath
7. Certificate of Service
8. Practice Notes
9. Sources and References

I. INTRODUCTORY STATEMENT AND AUTHORITY

[________________________________] ("Propounding Party"), by and through undersigned counsel, hereby propounds the following Interrogatories upon [________________________________] ("Responding Party") pursuant to Rule 33 of the Alaska Rules of Civil Procedure ("Alaska R. Civ. P.").

Response Deadline. Pursuant to Alaska R. Civ. P. 33(b), Responding Party must serve written answers and any objections within thirty (30) days after service of these Interrogatories. If a different time period has been ordered by the Court or stipulated to by the parties under Alaska R. Civ. P. 29, that period shall apply.

Interrogatory Limit. Pursuant to Alaska R. Civ. P. 33(a), the total number of written interrogatories, including all paragraphs and subparagraphs, shall not exceed thirty (30) without leave of court. This set contains [____] interrogatories (including all discrete subparts), which does not exceed the permitted limit.

Continuing Obligation. These Interrogatories are continuing in nature. Responding Party is required to supplement and amend responses promptly as required by Alaska R. Civ. P. 26(e) whenever additional or corrective information becomes available.

II. DEFINITIONS

For purposes of these Interrogatories, the following terms shall have the meanings set forth below. These definitions apply throughout regardless of capitalization:

A. "Action" means the above-captioned lawsuit pending in the Superior Court for the State of Alaska.

B. "Communication" means any oral, written, or electronic transmission of information, including but not limited to letters, memoranda, emails, text messages, instant messages, social media posts or messages, voicemails, telephone calls, video conferences, meetings, and face-to-face conversations.

C. "Concerning," "Relating to," or "Regarding" means directly or indirectly mentioning, referencing, describing, reflecting, evidencing, constituting, or in any way pertaining to the identified subject matter.

D. "Document" has the broadest meaning permitted under Alaska R. Civ. P. 34(a) and includes all writings, drawings, graphs, charts, photographs, sound recordings, images, electronically stored information ("ESI"), and other data or data compilations stored in any medium from which information can be obtained, translated, or converted into a reasonably usable form.

E. "Identify" or "State the Identity of" means:

• (i) For a natural person: state full legal name, all known aliases, present or last-known residential address, telephone number, email address, current employer, job title, and relationship to any party in this Action;
• (ii) For a business entity: state the full legal name, form of organization, state of formation, principal place of business address, and the identity of the individual(s) most knowledgeable about the subject matter;
• (iii) For a document: state the title or description, date, author(s), recipient(s), type (e.g., email, letter, report), Bates number (if applicable), and present custodian or location.

F. "Incident" means the events, occurrences, transactions, or omissions giving rise to this litigation as described in the Complaint filed on [__/__/____].

G. "Person" means any natural person, corporation, limited liability company, partnership, joint venture, association, governmental entity, or any other legal or business entity.

H. "You," "Your," or "Responding Party" means [________________________________], together with all present and former officers, directors, managing members, employees, agents, representatives, insurers, attorneys, experts, subsidiaries, affiliates, predecessors, successors, and any other Person acting or purporting to act on behalf of Responding Party.

III. INSTRUCTIONS

1. Answering Under Oath. Each Interrogatory must be answered separately and fully, in writing, under oath, by the party upon whom the Interrogatories are served. If the Responding Party is a corporation, partnership, association, or governmental agency, the answers shall be made by an officer or agent who shall furnish such information as is available to the party. See Alaska R. Civ. P. 33(a), (b).

2. Form of Answers. Each answer must restate the full text of the corresponding Interrogatory immediately before the response. Answers must be complete, responsive, and not evasive.

3. Objections. All objections must be stated with specificity. Boilerplate or generalized objections are insufficient. If an Interrogatory is objectionable in part, Responding Party must answer the non-objectionable portion and state the specific grounds for partial objection. See Alaska R. Civ. P. 33(b).

4. Privilege Log. If any responsive information is withheld on the basis of attorney-client privilege, work-product doctrine, or any other privilege or protection, Responding Party must provide a privilege log sufficient to enable the Propounding Party to assess the claim, identifying: (a) the nature and subject matter of the withheld information; (b) the date; (c) the participants in the communication or authors of the document; and (d) the specific privilege or protection asserted.

5. Supplementation. These Interrogatories are continuing in nature. Responding Party must promptly supplement any response that was incomplete or incorrect when made, or that becomes incomplete or incorrect due to subsequently acquired information. See Alaska R. Civ. P. 26(e).

6. Option to Produce Business Records. Where the answer to an Interrogatory may be derived or ascertained from business records and the burden of deriving the answer is substantially the same for either party, Responding Party may specify the records from which the answer may be derived and afford Propounding Party a reasonable opportunity to examine and copy such records. See Alaska R. Civ. P. 33(c).

7. Rules of Construction. The singular includes the plural and vice versa. The masculine, feminine, and neuter genders include each other. The connectives "and" and "or" shall be construed either disjunctively or conjunctively as necessary to bring within the scope of the Interrogatory all responsive information. "Including" means "including but not limited to."

8. Time Period. Unless otherwise specified, each Interrogatory covers the period from [__/__/____] through the date of Responding Party's response.

9. Computation of Time. All time periods shall be computed in accordance with Alaska R. Civ. P. 6(a).

IV. GENERAL INTERROGATORIES

INTERROGATORY NO. 1: Identification of Responding Party

State Your full legal name, all other names or aliases used during the past ten (10) years, date of birth, current residential address, current business address, all telephone numbers, and all email addresses used during the past five (5) years.

INTERROGATORY NO. 2: Persons Assisting in Preparation

Identify every Person who assisted, in whole or in part, in preparing the answers to these Interrogatories, and for each such Person, describe the subject matter of his or her contribution.

INTERROGATORY NO. 3: Fact Witnesses

Identify every Person who You believe has knowledge of any facts relevant to the claims or defenses in this Action, and for each such Person, describe the subject matter of his or her knowledge.

INTERROGATORY NO. 4: Factual Basis of Affirmative Defenses

State the complete factual basis for each affirmative defense asserted in Your Answer, identifying all Documents and witnesses that support each defense.

INTERROGATORY NO. 5: Factual Basis of Denials

For each material allegation in the Complaint that You denied in Your Answer, state the factual and legal basis for Your denial, and identify all Documents and witnesses supporting Your position.

INTERROGATORY NO. 6: Description of Incident

Describe in detail Your version of the Incident, including the date, time, location, weather conditions (if relevant), sequence of events, all Persons present or involved, all actions taken, and all conditions or circumstances You believe are relevant.

INTERROGATORY NO. 7: Insurance Coverage

Identify all insurance policies, excess or umbrella policies, or self-insured retention arrangements under which any insurer may be liable to satisfy all or part of a judgment in this Action or to indemnify or reimburse You for payments made to satisfy such judgment. For each, state: (a) the insurer's name and address; (b) the policy number; (c) the type of coverage; (d) the effective dates; (e) the limits of liability; (f) any applicable deductibles or self-insured retentions; and (g) any reservation-of-rights positions taken.

INTERROGATORY NO. 8: Expert Witnesses

Identify each expert witness You have retained, specifically consulted, or expect to call at trial, and for each, provide: (a) full name, address, and professional qualifications; (b) the subject matter on which the expert is expected to testify; (c) the substance of the facts and opinions to which the expert is expected to testify; (d) a summary of the grounds for each opinion; and (e) compensation arrangements. See Alaska R. Civ. P. 26(b)(4).

INTERROGATORY NO. 9: Statements and Recordings

Identify all statements (oral, written, or recorded) obtained by You or on Your behalf from any Person concerning the Incident or any issue in this Action. For each, state: (a) the date; (b) the identity of the declarant; (c) the identity of the person who took or recorded the statement; (d) the substance; and (e) the present custodian and location.

INTERROGATORY NO. 10: Prior Litigation

Identify every lawsuit, claim, arbitration, or administrative proceeding within the last ten (10) years in which You have been a party involving claims or facts similar to those in this Action. For each, state: (a) the case caption; (b) the court or agency; (c) the docket or case number; (d) the nature of the claims; and (e) the disposition or current status.

INTERROGATORY NO. 11: Damages

If You assert any counterclaim or seek damages of any kind, itemize and describe each category of damages claimed, including: (a) the amount claimed; (b) the method of calculation; and (c) the identity of all Documents and witnesses supporting each category.

INTERROGATORY NO. 12: Mitigation of Damages

If You contend that the Propounding Party failed to mitigate damages, state all facts supporting that contention, identify all Documents and witnesses supporting Your position, and explain the specific steps You contend should have been taken.

INTERROGATORY NO. 13: Third-Party Fault

If You contend that any Person other than Yourself caused or contributed to the damages alleged, identify each such Person and describe the factual and legal basis for that contention.

INTERROGATORY NO. 14: Communications with Propounding Party

Identify all Communications between You and the Propounding Party (or their agents or representatives) Concerning the subject matter of this Action. For each Communication, state: (a) the date; (b) the participants; (c) the medium; and (d) the substance.

INTERROGATORY NO. 15: Document Preservation

Describe all efforts undertaken by You to identify, preserve, and collect Documents and ESI relevant to this Action, including: (a) the date any litigation hold was issued; (b) the Person(s) responsible for overseeing preservation; (c) the scope of the hold; and (d) whether any potentially responsive information has been lost, destroyed, or deleted, and if so, the circumstances.

INTERROGATORY NO. 16: Investigations

Identify all investigations conducted by You or on Your behalf concerning the Incident or any claim or defense in this Action. For each, state: (a) the investigator's identity; (b) the dates of investigation; (c) the scope; and (d) the conclusions or findings (to the extent not privileged).

INTERROGATORY NO. 17: Photographs and Media

Identify all photographs, videos, audio recordings, surveillance footage, or other media recordings relating to the Incident, any party, or any issue in this Action. For each, state: (a) the date created; (b) the creator or source; (c) the subject matter; and (d) the present custodian or location.

INTERROGATORY NO. 18: Remedial Measures and Safety Policies

Describe any repairs, modifications, changes in policy or procedure, or other remedial measures taken after the Incident that relate to any issue in this Action. Additionally, describe all safety policies, procedures, or training programs that were in effect at the time of the Incident and are relevant to this Action. Identify all Documents embodying such measures and policies.

V. CASE-SPECIFIC INTERROGATORIES

The following blank interrogatories are provided for attorney customization. Ensure the total number of interrogatories, including all paragraphs and subparagraphs, does not exceed thirty (30) without leave of court under Alaska R. Civ. P. 33(a).

INTERROGATORY NO. [____]:

[________________________________]

INTERROGATORY NO. [____]:

[________________________________]

INTERROGATORY NO. [____]:

[________________________________]

INTERROGATORY NO. [____]:

[________________________________]

INTERROGATORY NO. [____]:

[________________________________]

VI. VERIFICATION / OATH

Instructions to Responding Party: Alaska Rule of Civil Procedure 33(b) requires that interrogatory answers be made under oath by the responding party. If the responding party is an entity, an officer or agent shall furnish the information under oath.

I, [________________________________], being duly sworn, depose and state that I am the ☐ individual party / ☐ [________________________________] (title/position) of [________________________________] (entity name); that I have read the foregoing Answers to Interrogatories and know the contents thereof; and that the answers are true, correct, and complete to the best of my knowledge, information, and belief.

Date: [__/__/____]

Signature: [________________________________]

Printed Name: [________________________________]

Title/Position (if entity): [________________________________]

STATE OF ALASKA

[________________________________] JUDICIAL DISTRICT

SUBSCRIBED AND SWORN TO before me this [____] day of [________________________________], 20[____].

Notary Public: [________________________________]

My Commission Expires: [__/__/____]

VII. CERTIFICATE OF SERVICE

I hereby certify that on [__/__/____], I served the foregoing [Plaintiff's/Defendant's] First Set of Interrogatories to [Opposing Party] upon all counsel of record and unrepresented parties via the method(s) indicated below, in accordance with Alaska R. Civ. P. 5(b):

Method of Service:

☐ Alaska Court System E-Filing / TrueFilng Electronic Service

☐ United States First-Class Mail, postage prepaid

☐ Hand Delivery

☐ Email (by written agreement of the parties)

☐ Certified Mail, Return Receipt Requested

☐ Other: [________________________________]

Served Upon:

Signature: [________________________________]

[________________________________]
Attorney for [Plaintiff/Defendant]
Alaska Bar No. [________________________________]
[________________________________] (Firm)
[________________________________] (Address)
[________________________________] (City, State, ZIP)
[________________________________] (Telephone)
[________________________________] (Email)

VIII. PRACTICE NOTES

1. Interrogatory Limit. Alaska R. Civ. P. 33(a) limits interrogatories to thirty (30) total, including all paragraphs and subparagraphs. Leave of court is required to exceed this limit. Draft interrogatories carefully to stay within the cap while obtaining maximum useful information.

2. Response Deadline. The standard response deadline is thirty (30) days after service. If service is by mail, add three (3) days under Alaska R. Civ. P. 6(e). Calendar the deadline immediately upon service.

3. Oath Requirement. Answers must be made under oath by the party, not merely signed by counsel. For entity parties, the officer or agent providing the answers must be personally sworn. Ensure the verification complies with the court's requirements.

4. Supplementation. Under Alaska R. Civ. P. 26(e), there is a continuing duty to supplement discovery responses. Advise clients of this obligation and document all supplemental responses.

5. Motion to Compel. If Responding Party fails to timely respond or provides evasive or incomplete answers, the Propounding Party may file a motion to compel under Alaska R. Civ. P. 37(a). The motion should include certification that counsel conferred or attempted to confer in good faith to resolve the dispute without court intervention.

6. Sanctions. Failure to serve timely, complete, and verified responses may result in sanctions under Alaska R. Civ. P. 37(b), including striking pleadings, precluding evidence, awarding attorney fees, or entering default judgment.

7. E-Filing Requirements. Check whether the assigned court location requires electronic filing through the Alaska Court System's TrueFilng platform or another approved method. Filing requirements may vary by judicial district.

8. Coordinating Discovery. Consider serving interrogatories in conjunction with requests for production (Rule 34) and requests for admission (Rule 36) to maximize discovery efficiency within the thirty-interrogatory limit.

9. Judicial District Considerations. Alaska has four judicial districts. Local practices and standing orders may vary. Check for any judge-specific discovery protocols or scheduling orders that modify standard deadlines or procedures.

IX. SOURCES AND REFERENCES

• Alaska Rules of Civil Procedure, Rules 5, 6, 26, 26(e), 29, 33, 34, 36, 37
• Alaska Rules of Civil Procedure (full text): https://public.courts.alaska.gov/web/rules/docs/civ.pdf
• Alaska Court System, Court Rules: https://courts.alaska.gov/rules/index.htm
• Alaska Court System, TrueFilng E-Filing: https://courts.alaska.gov/truefilung/
• Alaska Court System, Self-Help Discovery Information: https://courts.alaska.gov/selfhelp/debt/discovery.htm