State Court Discovery - Interrogatories

IN THE CIRCUIT COURT OF [____________] COUNTY, ARKANSAS

[____________] DIVISION

CASE NO.: [________________________________]

[PROPOUNDING PARTY]'S [FIRST / SECOND] SET OF INTERROGATORIES TO [RESPONDING PARTY]

TO: [RESPONDING PARTY], through [COUNSEL NAME / “the unrepresented party”].

Under Rules 26 and 33 of the Arkansas Rules of Civil Procedure, [PROPOUNDING PARTY] serves the following interrogatories on [RESPONDING PARTY].

1. Service and Response Information

Under Ark. R. Civ. P. 33(b)(3), answers or objections are due within 30 days after service of the interrogatories, except that a defendant receives the longer of 30 days after service of the interrogatories or 45 days after service of the summons and complaint. A court order or written agreement permitted by Rule 29 may set a shorter or longer time.

Interrogatories and answers ordinarily are not filed unless the court orders filing. Ark. R. Civ. P. 5(c). Preserve the served copy and proof of service.

2. Current Arkansas Rule Requirements

The Responding Party must:

1. repeat each interrogatory immediately before its answer or objection;
2. answer each interrogatory separately and fully in writing under oath unless objected to;
3. if objecting, state the particular reasons and answer every part that is not objectionable;
4. have the person making the answers sign them and counsel sign the objections;
5. avoid a blanket objection to the set; and
6. seasonably amend a materially incomplete or incorrect response when Rule 26(e) requires supplementation.

Rule 33(b)(4), amended effective June 4, 2026, states that merely calling an interrogatory irrelevant, disproportionate, or otherwise improper is insufficient. Grounds must be stated with particularity, and a ground omitted from a timely objection is waived unless the court excuses the failure for good cause.

3. Scope and Drafting Controls

Each retained interrogatory must seek nonprivileged matter relevant to a claim or defense and proportional to the needs of the case under Rule 26(b)(1). Before service, counsel should evaluate the issues, amount in controversy, relative access to information, party resources, importance of the discovery, and burden versus likely benefit.

Current Arkansas Rules 26(a) and 33 do not impose a fixed numerical limit on interrogatories. The court may limit discovery under Rule 26(c), and each request remains subject to relevance, proportionality, burden, certification, scheduling, and case-specific orders. Do not import the federal 25-interrogatory limit or the former template's unsupported 30-interrogatory cap.

4. Definitions

Use only definitions needed for the retained questions.

1. “Action” means this above-captioned case.
2. “You” or “Responding Party” means [FULL NAME]. For an entity, the answers must provide information available to the entity through an officer or agent as stated in Rule 33(a); these terms do not automatically erase privilege, possession, or proportionality limits.
3. “Occurrence” means [PRECISE EVENT / TRANSACTION / CONDUCT], on or about [DATE], at [LOCATION].
4. “Agreement” means the [TITLE / DATE / PARTIES] agreement at issue.
5. “Communication” means an oral, written, or electronic transmission of information. A retained interrogatory should state the people, subject, and date range relevant to that question.
6. “Identify,” when used for a person, means state the person's full name, last known contact information, relationship to the Action, and the subject of the person's relevant knowledge.
7. “Identify,” when used for a document or ESI, means state enough information to locate and distinguish it, including its type, date, author or sender, recipient, general subject, and present custodian. Use a separate Rule 34 request to obtain a copy.

5. Instructions

1. Answer from information reasonably available to the Responding Party. If an answer is presently incomplete, identify the completed inquiry, the missing information, and when supplementation is expected.
2. If only part of an interrogatory is objectionable, answer the unobjectionable part.
3. If withholding otherwise discoverable information based on privilege or trial-preparation protection, make the claim expressly and describe the nature of what is withheld, without revealing the protected information, sufficiently to allow assessment under Rule 26(f)(1). Do not demand a categorical document-by-document log where the rule and circumstances do not require one.
4. If relying on business records under Rule 33(d), specify the records in enough detail for the requesting party to locate and identify them as readily as the responding party, and provide a reasonable opportunity to examine, audit, inspect, and copy them. The business-record option applies only when the burden of deriving the answer is substantially the same for both parties.
5. Supplement or correct responses as required by Rule 26(e).
6. The signature required by Rule 26(g) certifies the discovery request after reasonable inquiry. Delete any request that is inconsistent with the rules, interposed for an improper purpose, or unreasonable or unduly burdensome in light of the case.

6. Interrogatories

Interrogatory No. 1 — Persons with Relevant Knowledge

Identify each person known to You who has knowledge relevant to [SPECIFIC CLAIM / DEFENSE / EVENT], and state the subject of that knowledge.

Interrogatory No. 2 — Your Account of the Occurrence

Describe the acts, omissions, events, dates, and participants on which You base Your account of the Occurrence.

Interrogatory No. 3 — Factual Basis for Pleaded Position

State the material facts supporting [IDENTIFY ONE CLAIM, DENIAL, OR AFFIRMATIVE DEFENSE BY PARAGRAPH], and identify the persons and documents on which You rely.

Interrogatory No. 4 — Other Allegedly Responsible Persons

If You contend that a person other than [NAMED PARTY] caused or contributed to [IDENTIFIED HARM], identify that person and state the material facts supporting the contention.

Interrogatory No. 5 — Relevant Communications

Identify each Communication between [SPECIFIED PEOPLE] from [START DATE] through [END DATE] concerning [NARROW SUBJECT], stating the date, participants, method, and general subject.

Interrogatory No. 6 — Documents and ESI

Identify the documents or ESI on which You rely concerning [NARROW SUBJECT / PLEADED POSITION], and state the present custodian. This interrogatory requests identification only; any demand for production should be made under Rule 34.

Interrogatory No. 7 — Damages or Monetary Relief

For each category of damages or monetary relief You seek, state the amount claimed or present estimate, the method of computation, and the supporting information or records.

Interrogatory No. 8 — Insurance Agreement

Identify each insurance agreement within Rule 26(b)(2) under which a person carrying on an insurance business may be liable to satisfy part or all of a judgment in this Action or to indemnify or reimburse for payments made to satisfy the judgment, stating the insurer, named insured, policy number, coverage type, and applicable limits.

Interrogatory No. 9 — Expected Testifying Experts

For each person You expect to call as an expert witness at trial, state the subject matter of the expected testimony, the substance of the facts and opinions, and a summary of the grounds for each opinion.

Interrogatory No. 10 — Statements

Identify each written, adopted, recorded, or substantially verbatim contemporaneously recorded statement by [REQUESTING PARTY / NAMED PERSON] concerning [SUBJECT], stating its date, maker, method, and custodian.

Interrogatory No. 11 — Policies, Procedures, or Training

Identify each policy, procedure, or training material in effect on [DATE] that You contend governed [SPECIFIED CONDUCT], stating its title, effective date, and responsible custodian.

Interrogatory No. 12 — Contract Performance

For each contractual obligation You contend [PARTY] failed to perform, identify the provision, describe the alleged failure, state when performance was due, and identify the supporting persons and records.

Interrogatory No. 13 — Mitigation

If You contend that [PARTY] failed to mitigate [IDENTIFIED DAMAGE], state the material facts supporting that contention and identify the persons and records on which You rely.

Interrogatory No. 14 — Lost, Destroyed, or Unavailable Information

Identify any information responsive to these interrogatories that You know was lost, destroyed, altered, or became unavailable after [RELEVANT DATE], and state its nature, former custodian, approximate date and circumstances of the loss or change, and any known source of an equivalent copy.

Interrogatory No. 15 — Persons Supplying Answers

Identify each person who supplied substantive information used to prepare the answers and state the interrogatory numbers for which that person supplied information. Do not disclose privileged communications or attorney work product.

7. Propounding Party's Signature

Respectfully served on [__/__/____].

Signature: __________________________________

[ATTORNEY NAME], Ark. Bar No. [________]

Attorney for [PROPOUNDING PARTY]

[FIRM NAME]

[ADDRESS]

[EMAIL] | [PHONE]

8. Certificate of Service

I certify that on [__/__/____], I served a true and correct copy of these Interrogatories on the following counsel of record or unrepresented party by [METHOD AUTHORIZED UNDER ARK. R. CIV. P. 5(b)]:

Name: [________________________________]

Address / email: [________________________________]

Party represented: [________________________________]

Signature: __________________________________

[ATTORNEY / SELF-REPRESENTED PARTY NAME]

Pre-Service Checklist

☐ Caption, parties, case number, set number, and recipient are correct.

☐ Each question is relevant to a claim or defense and proportional under current Rule 26(b)(1).

☐ Scheduling orders, protective orders, and prior discovery were reviewed.

☐ No federal or out-of-state numerical limit was imported; burden and cumulative discovery were evaluated.

☐ Settlement communications, privileged material, protected trial-preparation material, medical information, personnel data, and confidential information were screened before retaining a question.

☐ Every interrogatory has one clear target and a reasonable subject and date range.

☐ Requests for copies were moved to a Rule 34 production request.

☐ The Rule 33(b)(3) response date was calculated from actual service dates and any order or written agreement.

☐ The request is signed with all Rule 26(g) contact information.

☐ Service complies with Rule 5(b), proof complies with Rule 5(e), and the discovery will not be filed unless ordered.

Sources and References

• Arkansas Judiciary, Arkansas Rules of Civil Procedure, current through June 4, 2026.
• Arkansas Judiciary, Court Rules navigation — current rules collection.

Current official rules verified August 2, 2026. Polite direct requests to arcourts.gov timed out and the official Lexum rules repository returned 403; the same official Arkansas Judiciary/Lexum URLs were fetched through Sofya. Rule 26 and Rule 33 were amended effective June 4, 2026.