Connecticut State Court Discovery Interrogatories

SUPERIOR COURT OF THE STATE OF CONNECTICUT

JUDICIAL DISTRICT OF [________________________________]

AT [________________________________]

Docket No.: [________________________________]

Return Date: [__/__/____]

[________________________________],
Plaintiff,

v.

[________________________________],
Defendant.

PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT

ATTORNEY INFORMATION

Propounding Attorney:

Date of Certification: [__/__/____]

I. INTRODUCTORY STATEMENT

Pursuant to the Connecticut Practice Book ("CPB") Sections 13-2 through 13-6 and all other applicable provisions of Connecticut law, Plaintiff [________________________________] hereby propounds the following Interrogatories upon Defendant [________________________________]. Each Interrogatory must be answered separately and fully, in writing and under oath, within the time prescribed by the Practice Book.

Response Deadline

Under CPB Section 13-7, Defendant must serve sworn answers upon the Plaintiff within thirty (30) days from the date of certification of service of these Interrogatories. If objections are filed to any Interrogatories, answers to the remaining unobjectionable Interrogatories must still be served within sixty (60) days of the date of certification of service. See CPB Section 13-7(a).

Interrogatory Scope

In all civil actions not governed by mandatory standard interrogatory forms (CPB Sections 13-6(c) through (g)), parties may serve non-standard interrogatories addressing any matter within the scope of discovery permitted by CPB Sections 13-2 through 13-5. For personal injury motor vehicle actions, premises liability, and certain other specified categories, mandatory standard interrogatory forms apply. See CPB Section 13-6 and Appendix of Forms (Forms 201-221).

Continuing Obligation

These Interrogatories are continuing in nature. Defendant must seasonably supplement or amend responses whenever additional or corrective information becomes available, consistent with the duty of candor and good faith imposed by the Practice Book.

II. DEFINITIONS

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

1. "You," "Your," or "Defendant" means [________________________________], including all present and former parents, subsidiaries, affiliates, divisions, officers, directors, managers, members, partners, employees, agents, representatives, attorneys, and all other persons or entities acting or purporting to act on Defendant's behalf.

2. "Plaintiff" means [________________________________], including its agents, representatives, and attorneys.

3. "Document" or "Documents" has the broadest meaning permissible under the CPB, including 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 if necessary into reasonably usable form. This includes drafts, non-identical copies, and associated metadata.

4. "Communication" means any transmission of information by any means, whether oral, written, or electronic, including but not limited to letters, memoranda, emails, text messages, instant messages, voicemails, social media messages, telephone conversations, and face-to-face discussions.

5. "Identify" when used with respect to:

• (a) A natural person -- state the person's full legal name, present or last-known address, telephone number, email address, employer and job title, and relationship to any party in this action.
• (b) A business or other entity -- state its full legal name, form of organization, jurisdiction of formation, address of its principal place of business, and the identity of its representative most knowledgeable about the subject matter in question.
• (c) A document -- state its title, date, author(s), addressee(s), recipient(s), type (e.g., letter, email, contract), general subject matter, and the identity of its present custodian.

6. "Incident" means the events, acts, omissions, and circumstances giving rise to this action, as described in the Complaint.

7. "Relevant Period" means the time period from [__/__/____] through the present, unless otherwise specified in an individual Interrogatory.

8. "Person" means any natural person, corporation, limited liability company, partnership, association, governmental body, or any other legal entity.

9. "Concerning" or "Relating to" means referring to, describing, evidencing, constituting, mentioning, reflecting, connected with, commenting on, regarding, or pertaining to, in whole or in part.

III. INSTRUCTIONS

1. Answer each Interrogatory separately and fully, in writing and under oath, pursuant to CPB Section 13-7. Each answer must be preceded by the full text of the Interrogatory to which it responds.

2. If any Interrogatory is objected to in whole or in part, state with specificity the grounds for each objection and, pursuant to CPB Section 13-8, serve such objections within sixty (60) days of the date of certification of service. Answers to unobjectionable Interrogatories must still be served within sixty (60) days.

3. If You withhold any information on the basis of attorney-client privilege, work-product doctrine, or any other privilege or protection, You must: (i) expressly identify the privilege claimed; and (ii) provide a privilege log sufficient to permit assessment of the claim, including the nature of the document, its date, author(s), recipient(s), general subject matter, and the specific privilege asserted. See CPB Section 13-5.

4. Whenever knowledge or information contained in an answer is not within Your personal knowledge, identify the person(s) who possess such knowledge and the source of the information provided.

5. An answer stating that You lack sufficient information or knowledge to respond must detail the efforts made to obtain the information.

6. These Interrogatories are deemed continuing. If You obtain additional responsive information after serving Your answers, You must promptly supplement or correct responses.

7. The singular shall include the plural and vice versa; the masculine shall include the feminine and neuter and vice versa; "and" shall include "or" and vice versa, as necessary to make each Interrogatory inclusive rather than exclusive.

8. Unless otherwise specified, these Interrogatories cover the Relevant Period defined above.

9. Where an Interrogatory asks You to "identify" or "describe," provide all information within Your possession, custody, or control, including information held by Your agents, employees, accountants, or attorneys (except information protected by valid privilege).

IV. INTERROGATORIES

Interrogatory No. 1:
Identify every person who participated in preparing, reviewing, or supplying information for the answers to these Interrogatories, and describe each person's role and the specific Interrogatories for which each person provided information.

Interrogatory No. 2:
State Your full legal name, all trade names, assumed names, or d/b/a designations used within the past ten (10) years, Your current business address, and Your form of organization.

Interrogatory No. 3:
Identify all persons known to You who have knowledge of any facts relevant to the claims or defenses in this action, and for each such person provide: (a) their full name and contact information; (b) the subject matter(s) of their knowledge; and (c) whether they were a percipient witness to any specific event described in the pleadings.

Interrogatory No. 4:
State in detail the factual basis for each affirmative defense asserted in Your Answer, including identification of every fact, Document, and witness upon which You rely to support each defense.

Interrogatory No. 5:
State the complete factual basis for Your denial of each material allegation contained in the Complaint. For each denial, identify the Documents and witnesses that support Your position.

Interrogatory No. 6:
Describe with particularity each Communication between You and Plaintiff (or Plaintiff's agents or representatives) Concerning the subject matter of this litigation, stating for each Communication: (a) the date; (b) all participants; (c) the medium; and (d) the substance.

Interrogatory No. 7:
State in detail the chronology of events that You contend gave rise to the dispute, including the date, location, participants, and outcome of each relevant event.

Interrogatory No. 8:
Identify all agreements, whether written or oral, between You and Plaintiff that relate to the subject matter of this action, stating for each: (a) the date of the agreement; (b) the parties; (c) the general subject matter; and (d) whether the agreement is written and, if so, its present custodian.

Interrogatory No. 9:
Describe the policies, procedures, guidelines, or training materials in effect during the Relevant Period that relate to [________________________________], and identify each Document comprising those policies.

Interrogatory No. 10:
Identify all insurance policies (including primary, excess, umbrella, and surplus lines) that may provide coverage for the claims asserted in this action. For each policy, state: (a) the name and address of the insurer; (b) the policy number; (c) the policy period; (d) the per-occurrence and aggregate limits of liability; (e) applicable deductible or self-insured retention; and (f) whether notice of claim has been provided to the insurer.

Interrogatory No. 11:
State the total amount of damages You claim to have sustained as a result of any conduct by Plaintiff, itemizing each element of damages and the method of calculation for each element, and identifying all Documents supporting the claimed damages.

Interrogatory No. 12:
If You contend that Plaintiff failed to mitigate damages, describe all facts supporting that contention, and identify all supporting witnesses and Documents.

Interrogatory No. 13:
If You contend that any third party is wholly or partially responsible for the injuries or damages alleged by Plaintiff, identify each such third party and state the factual and legal basis for Your contention.

Interrogatory No. 14:
Describe Your document retention and destruction policies applicable during the Relevant Period, including: (a) the types of Documents subject to scheduled destruction; (b) the applicable retention periods; and (c) whether a litigation hold was issued in connection with this matter, and if so, the date issued, the person(s) who issued it, and the scope of the hold.

Interrogatory No. 15:
Identify each expert witness You have retained or expect to call at trial, and for each expert state: (a) the expert's full name, business address, and 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; and (d) a summary of the grounds for each opinion.

Interrogatory No. 16:
Identify every electronic device, server, cloud storage account, or other storage medium in Your possession, custody, or control that contains or may contain Documents or ESI relevant to the claims or defenses in this action, and describe the steps taken to preserve such ESI.

Interrogatory No. 17:
Identify all prior lawsuits, administrative proceedings, or regulatory investigations in which You have been a party within the past ten (10) years involving claims similar to those asserted in this action, stating for each: (a) the tribunal; (b) the case caption and docket number; (c) the nature of the claims; and (d) the disposition.

Interrogatory No. 18:
Describe each Communication between You and any non-party witness Concerning this lawsuit or the events giving rise to it, including the date, participants, medium, and substance of each Communication.

Interrogatory No. 19:
List all social media accounts maintained by You or any of Your agents that contain content related to the allegations of the Complaint, identifying the platform, account name, and date ranges of relevant posts or messages.

Interrogatory No. 20:
Identify each Document You intend to use as an exhibit at trial and state the purpose for which each will be offered.

V. CASE-SPECIFIC INTERROGATORIES

The following blank interrogatories are provided for case-specific questions tailored to the particular claims and defenses at issue.

Interrogatory No. 21:
[________________________________]

Interrogatory No. 22:
[________________________________]

Interrogatory No. 23:
[________________________________]

Interrogatory No. 24:
[________________________________]

Interrogatory No. 25:
[________________________________]

VI. VERIFICATION

VERIFICATION OF DEFENDANT'S ANSWERS

(To be completed by the responding party when answering)

I, [________________________________], being duly sworn, depose and say that:

☐ I am the Defendant in the above-captioned action.

☐ I am the [________________________________] (title/position) of Defendant [________________________________] and am authorized to make this verification on Defendant's behalf.

I have read the foregoing Answers to Plaintiff's First Set of Interrogatories and know the contents thereof. The answers are true and complete to the best of my knowledge, information, and belief.

Signature: [________________________________]
Printed Name: [________________________________]
Title/Capacity: [________________________________]
Date: [__/__/____]

NOTARIZATION

STATE OF CONNECTICUT
COUNTY OF [________________________________]

Subscribed and sworn to before me this [____] day of [________________________________], 20[____].

Signature: [________________________________]
Notary Public / Commissioner of the Superior Court
My Commission Expires: [__/__/____]

VII. CERTIFICATE OF SERVICE

I hereby certify that on [__/__/____], a copy of the foregoing Plaintiff's First Set of Interrogatories to Defendant was served upon counsel of record for Defendant by the method indicated below, in compliance with Connecticut Practice Book Section 10-12:

Method of Service:

☐ Hand delivery
☐ First-class United States mail, postage prepaid
☐ Certified mail, return receipt requested
☐ Electronic service via the Judicial Branch e-filing system
☐ Email (by agreement of the parties)
☐ Other: [________________________________]

Served Upon:

[________________________________], Esq.
[________________________________] (Firm Name)
[________________________________] (Street Address)
[________________________________] (City, State, ZIP)
[________________________________] (Telephone)
[________________________________] (Email)
Juris No.: [________________________________]

Signature: [________________________________]
[________________________________], Esq.
Counsel for Plaintiff
[________________________________] (Firm Name)
[________________________________] (Street Address)
[________________________________] (City, State, ZIP)
[________________________________] (Telephone)
[________________________________] (Email)
Juris No.: [________________________________]

VIII. PRACTICE NOTES

A. Connecticut-Specific Discovery Considerations

1. Standard vs. Non-Standard Interrogatories. Connecticut Practice Book Section 13-6 distinguishes between standard form interrogatories (applicable to specific case types such as motor vehicle personal injury, premises liability, and product liability) and non-standard interrogatories. For cases subject to standard forms, practitioners must use the forms in the Appendix of Forms (Forms 201-221). This template is designed for cases where non-standard interrogatories are appropriate.

2. No Fixed Numerical Limit on Non-Standard Interrogatories. Unlike many other jurisdictions, the Connecticut Practice Book does not impose a specific numerical cap on non-standard interrogatories. However, interrogatories must be relevant and proportional to the needs of the case, and the Court may limit discovery under CPB Section 13-5 if it is unreasonably cumulative, duplicative, or burdensome.

3. Response and Objection Deadlines. Under CPB Section 13-7, answers are due within 30 days of certification of service. Objections must be filed within 60 days. If objections are raised as to some interrogatories, answers to the remaining unobjectionable interrogatories are also due within 60 days.

4. Motions for Order of Compliance. If Defendant fails to answer or provides inadequate answers, Plaintiff may file a Motion for Order of Compliance under CPB Section 13-14. The motion must include a certification that the movant has made a good-faith effort to resolve the discovery dispute before seeking court intervention.

5. Sanctions. Failure to comply with discovery orders may result in sanctions, including adverse inferences, preclusion of evidence, striking of pleadings, or entry of default. See CPB Section 13-14; Connecticut General Statutes Section 52-197.

6. Privilege Logs. When withholding information based on privilege, the responding party must provide sufficient information to enable assessment of the claim, consistent with CPB Section 13-5 and applicable case law.

B. Filing and Service Notes

7. No Filing with Court. Under standard practice, interrogatories and answers are not filed with the court. They are served directly on the opposing party. Interrogatories may be filed only when relevant to a pending motion (e.g., motion for order of compliance, motion for summary judgment).

8. Electronic Filing. Connecticut Superior Court uses electronic filing through the Judicial Branch e-filing system. Verify whether electronic service is available and mandatory in the applicable Judicial District.

9. Judicial District Practices. Individual Judicial Districts may have local practices or standing orders affecting discovery procedures. Check for any applicable orders issued by the presiding judge.

10. Scheduling Orders. Review any applicable scheduling order or case management plan for discovery deadlines that may differ from the default Practice Book timelines.

IX. SOURCES AND REFERENCES

• Connecticut Practice Book Section 13-2 -- Scope of Discovery
• Connecticut Practice Book Section 13-5 -- Privilege and Work Product
• Connecticut Practice Book Section 13-6 -- Interrogatories; In General
• Connecticut Practice Book Section 13-7 -- Answers to Interrogatories
• Connecticut Practice Book Section 13-8 -- Objections to Interrogatories
• Connecticut Practice Book Section 13-14 -- Order for Compliance; Failure to Answer or Comply
• Connecticut General Statutes Section 52-197 -- Discovery; Interrogatories
• Connecticut Judicial Branch Official Website: https://www.jud.ct.gov
• Connecticut Practice Book (2026 Edition): https://www.jud.ct.gov/publications/PracticeBook/PB.pdf

This template is designed for use in Connecticut Superior Court for cases where non-standard interrogatories are appropriate. For cases governed by mandatory standard interrogatory forms (motor vehicle personal injury, premises liability, etc.), practitioners must use the applicable Appendix Forms. Verify all Practice Book citations, confirm any applicable Judicial District standing orders, and tailor interrogatories to the specific claims and defenses at issue.