State Court Discovery - Interrogatories

ALABAMA INTERROGATORY DRAFTING WORKSHEET

DO NOT SERVE THIS WORKSHEET AS-IS. The current rules, local practice, case-management orders, discovery plan, protective orders, and service record control the final document.

1. Case and Discovery Control Sheet

• ☐ Counsel confirmed the final count, including how subparts are treated.
• ☐ The summons, pleadings, docket, schedule, and every discovery order were checked for a different deadline or limit.
• ☐ The official rules source and its currency date were recorded before drafting the service copy.

2. Caption

3. Definitions and Instructions Drafting

Use only definitions and instructions that are necessary, accurate, and consistent with the controlling rules and orders.

Do not define "you" to include counsel, every affiliate, or every present and former agent unless the controlling scope and the facts support that definition.

4. Interrogatory Selection Bank

These prompts are drafting leads, not preapproved discovery. Counsel must narrow each prompt to the pleaded issues, controlling scope, burden, confidentiality, and question limit.

5. Sensitive and High-Burden Request Screen

6. Count and Burden Review

7. Response-Document Design

Select the format required or permitted by current authority:

• ☐ separate propounding paper only;
• ☐ answer spaces after each interrogatory;
• ☐ restated interrogatory followed by answer or objection;
• ☐ court form;
• ☐ electronic discovery platform format; or
• ☐ other: [DESCRIPTION].

Required verification text and signer: [________________________________]

Objection specificity and partial-answer treatment: [________________________________]

Privilege or protection information and due date: [________________________________]

8. Execution, Filing, and Service Module

Insert only the signature, verification, filing, and service language required by current authority and the case orders.

Attorney / party name: [________________________________]

Capacity: [________________________________]

Signature: ____________________________________

Date: [__/__/____]

Required verification text and signer: [________________________________]

Authorized officer / notary, if required: [________________________________]

Service date and time: [________________________________]

Permitted service method: [________________________________]

Recipients and addresses: [________________________________]

Filing required, prohibited, or deferred: [________________________________]

Receipt or proof retained: [________________________________]

9. Final Do-Not-Serve Checklist

• ☐ Every interrogatory is tied to a pleaded issue and narrowed to the controlling discovery scope.
• ☐ The final count, subparts, deadline, objections, privilege, supplementation, expert, verification, filing, and service rules were checked against current official authority and orders.
• ☐ No federal discovery default or another state's rule was imported.
• ☐ The final document uses the response format required by the controlling procedure.
• ☐ Confidential, medical, financial, trade-secret, personal, and identity information is protected under the case-specific process.
• ☐ The served copy contains no drafting alternatives, blank authority fields, or unused question-bank rows.