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

Count and deadline control. Before service, enter the governing rule or order [CITATION], cumulative interrogatory count and subpart method [DETAILS], leave, stipulation, or local-limit status [DETAILS], service date and method [DETAILS], response period [DETAILS], and calculated response date [DATE]. This form states no default number or period.

Interrogatory Scope

Supplementation control. Apply only the duty supplied by the current governing rule, order, or agreement: [CITATION / TERMS / NONE IDENTIFIED]. Do not label these interrogatories “continuing” or demand supplementation beyond that authority.

Section 13-15 governs supplemental or corrected compliance after a party discovers new material previously requested and ordered subject to discovery, or learns that prior compliance was incorrect or is no longer true under the rule's stated conditions.

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 meaning incorporated into every discovery request by CPB Section 13-1(b)-(c): any writing, drawing, graph, chart, photograph, sound recording, image, or other data or data compilation stored in any medium from which information can be obtained directly or, if necessary, after translation by the responding party into a reasonably usable form. A draft or nonidentical copy is a separate document, and a request for documents encompasses ESI unless otherwise specified.

4. "Communication" means the transmittal of information in the form of facts, ideas, inquiries, or otherwise, as provided by CPB Section 13-1(c)(1).

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 or any business, legal, or governmental entity or association, as provided by CPB Section 13-1(c)(7).

9. "Concerning" or "Relating to" means relating to, referring to, describing, evidencing, or constituting, as provided by CPB Section 13-1(c)(8).

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.

3. If You withhold responsive information on privilege or work-product grounds, file the specific objection required by CPB Section 13-8 and state whether information is withheld. Upon the requesting party's request, comply with the privilege-log requirements and forty-five-day timing in CPB Section 13-3(d), subject to that rule's exceptions.

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. Comply with the continuing-disclosure requirements of CPB Section 13-15 when its conditions are met.

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: [__/__/____]

Response-verification control

The propounding paper does not prescribe a verification method. Before answers are served, enter the current rule or order, authorized signer, oath or declaration text, and any jurat requirement: [DETAILS]. Delete unused oath, declaration, and notary options.

VII. CERTIFICATION OF SERVICE

I certify that a copy of this document was or will immediately be mailed or delivered electronically or nonelectronically on [__/__/____] to all attorneys and self-represented parties of record and that written consent for electronic delivery was received from all attorneys exempt from e-filing and self-represented parties of record who received or will immediately be receiving electronic delivery.

Signature of attorney or self-represented party: ________________________________________

Printed name: [________________________________]

Mailing address or email address: [________________________________]

Date signed: [__/__/____]

Telephone: [________________________________]

This certification tracks Practice Book § 10-14(a) as amended effective January 1, 2026. Section 10-13 controls the permitted method and when electronic delivery is required or requires written consent.

VIII. CURRENT PRACTICE NOTES

1. Case-type gate. Use the mandatory standard forms listed in § 13-6(b) for the specified motor-vehicle, premises-liability, consortium, and uninsured/underinsured-motorist actions unless the judicial authority permits otherwise. Medical-negligence cases use Forms 218, 220, and 221 plus twenty additional interrogatories as of right without subparts under § 13-6(c).
2. No general numerical cap. Outside the standard-form case categories, § 13-6(b) states that the frequency of interrogatories is not limited unless the judicial authority orders otherwise.
3. Sixty-day response period. Section 13-7(a) measures the default answer period from the date of certification of service. The same sixty-day period governs timely objections unless changed under the rule.
4. Answers and objections. Answers are under oath, repeat each interrogatory, are signed, and are served rather than filed. Objections set out the interrogatory, give specific reasons, say whether information is withheld, are signed, and are filed with the court.
5. Privilege log. Section 13-8(b) incorporates § 13-3(d) when information is withheld for privilege or work product. The log follows a request by the party serving discovery and is due within forty-five days from that request, subject to the rule's exceptions.
6. Continuing disclosure. Section 13-15 applies only under its stated conditions and calls for prompt notice plus filed and served supplemental or corrected compliance.
7. Compliance motion. Section 13-7(e) permits a motion under § 13-14 for failure to answer. Before an interrogatory objection is placed on the short calendar, § 13-8(c) requires the specified affidavit concerning bona fide attempts to resolve the objection.
8. Proportional sanctions. Section 13-14 authorizes an order proportional to the noncompliance and lists compliance, motion costs and a reasonable attorney fee, established facts, evidentiary preclusion, and dismissal, nonsuit, or default.
9. Scheduling controls. Confirm any case-management order, standing order, stipulation, and assigned trial date before setting a response or motion date.

IX. VERIFIED SOURCE FOR THIS CORRECTION

Connecticut Judicial Branch, Official 2026 Connecticut Practice Book, §§ 10-12 through 10-14; 13-2 through 13-8; 13-14 through 13-15; and Appendix Forms 201–221 (accessed July 30, 2026):

https://www.jud.ct.gov/Publications/PracticeBook/PB.pdf

This file received a targeted rule-correction pass only and is not stamped as fully verified. Tailor each interrogatory to the operative claims and defenses and review the entire request set before service.