[COURT HEADER]
SUPERIOR COURT OF THE STATE OF CONNECTICUT
JUDICIAL DISTRICT OF [JUDICIAL DISTRICT]
AT [VENUE]

[PLAINTIFF NAME(S)],
Plaintiff(s),

v. Docket No. [DOCKET NUMBER]

[DEFENDANT NAME(S)],
Defendant(s).

_______/

PLAINTIFF’S [FIRST/SECOND] SET OF INTERROGATORIES TO [DEFENDANT NAME]

Effective Date: [DATE]
Jurisdiction: Connecticut State Courts

[// GUIDANCE: Replace bracketed placeholders with matter-specific details. Verify compliance with the Connecticut Practice Book (“CPB”) provisions on discovery—particularly the numerical limit on interrogatories and the default response time. At the time of drafting, the CPB permits a maximum of twenty-five (25) interrogatories, including subparts, without prior court approval. Confirm the current limit before service.]

TABLE OF CONTENTS
I. Preliminary Statement
II. Definitions
III. General Instructions
IV. Specific Interrogatories (Nos. 1-[__])
V. Verification
VI. Certificate of Service

I. PRELIMINARY STATEMENT
Plaintiff, pursuant to the Connecticut Practice Book and all other applicable Connecticut law, propounds the following Interrogatories to Defendant. Each Interrogatory must be answered separately and fully, in writing and under oath, within the time prescribed by the CPB (currently [30] days from service, unless the parties stipulate or the Court orders otherwise).

II. DEFINITIONS
For purposes of these Interrogatories, the following terms have the meanings set forth below. These definitions apply regardless of whether the term is capitalized herein.

A. “You,” “Your,” or “Defendant” means [DEFENDANT NAME], all predecessors, successors, parents, subsidiaries, affiliates, divisions, officers, directors, employees, agents, representatives, and all other persons acting or purporting to act on its behalf.
B. “Plaintiff” means [PLAINTIFF NAME] and any predecessor, successor, parent, subsidiary, affiliate, division, officer, director, employee, agent, representative, or other person acting or purporting to act on Plaintiff’s behalf.
C. “Document” and “Documentation” are used in the broadest sense permissible under the CPB, and include electronically stored information (“ESI”), e-mails, writings, drawings, graphs, charts, photographs, recordings, and any other data compilations, whether stored in hard copy or electronic form, together with any metadata.
D. “Communication” means any transmission of information, whether oral, written, or electronic, including but not limited to letters, memoranda, e-mails, text messages, instant messages, voicemails, and social media postings.
E. “Identify” or “State the identity of” when used with respect to:
1. A natural person—requires the person’s full name, present or last known address, present or last known telephone number, and relationship to the parties.
2. A business or other entity—requires its full name, address of headquarters and principal place of business, form of organization, and the identity of any person(s) with knowledge of the matter referenced.
3. A document—requires its title, date, author(s), recipient(s), type (e.g., letter, e-mail), and present custodian.

III. GENERAL INSTRUCTIONS

1. Answer each Interrogatory separately and fully, in writing and under oath.
2. If You object to any Interrogatory or subpart, state with specificity the grounds for the objection, and answer the remainder of the Interrogatory to the extent it is not objectionable.
3. If You withhold any information based upon a claim of privilege, work-product protection, or other immunity, identify each item withheld and state the specific grounds for the claim. Provide a privilege log that complies with the CPB’s requirements.
4. These Interrogatories are deemed continuing; You must seasonably supplement Your responses in accordance with the CPB when You obtain additional responsive information.
5. Unless otherwise specified, the relevant time period is from [START DATE] through the present.
6. Singular includes plural and vice versa; masculine, feminine, and neutral pronouns include each of the others.
7. “And” as well as “or” shall be construed conjunctively or disjunctively as necessary to make the request inclusive rather than exclusive.

IV. SPECIFIC INTERROGATORIES
[// GUIDANCE: The template provides 20 core Interrogatories—well within the standard CPB limit of 25. Add or delete as needed, ensuring the total (with subparts) does not exceed the current rule without court approval.]

Interrogatory No. 1
Identify every person who prepared or assisted in preparing the answers to these Interrogatories and state the nature of each person’s assistance.

Interrogatory No. 2
Identify all persons known to You who have knowledge of any facts alleged in the pleadings, and for each such person state the specific area(s) of knowledge.

Interrogatory No. 3
State in detail the factual basis for each affirmative defense asserted in Your [Answer/Responsive Pleading].

Interrogatory No. 4
Describe with specificity all communications between You and Plaintiff concerning the subject matter of this litigation, including the date, participants, and substance of each communication.

Interrogatory No. 5
Identify all documents that support or refute Your defenses to Plaintiff’s claims.

Interrogatory No. 6
State the complete factual basis for Your denial of each material allegation contained in Plaintiff’s [Complaint/Amended Complaint].
a. For each denial, identify the documents and witnesses that support Your position.

Interrogatory No. 7
Describe in detail the chronology of events that You contend gave rise to this dispute, including dates, participants, and actions taken.

Interrogatory No. 8
Identify all agreements, written or oral, between You and Plaintiff that relate to the subject matter of this action.

Interrogatory No. 9
State the amount of any damages You contend were caused by Plaintiff, itemizing each element of damage, the method of calculation, and all documents supporting each element.

Interrogatory No. 10
Identify all insurance policies that may provide coverage for the claims asserted in this lawsuit, and for each such policy state the carrier, policy number, limits of liability, and whether notice of claim has been provided.

Interrogatory No. 11
State whether You contend any third party is liable to Plaintiff or to You for the claims asserted herein, and describe the factual and legal basis for such contention.

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

Interrogatory No. 13
Describe any efforts You have made to preserve documents and electronic data related to the subject matter of this action, including the date litigation hold notices were issued and the scope of such notices.

Interrogatory No. 14
Identify any expert witness You expect to call at trial, stating the expert’s qualifications, subject matter of testimony, substance of facts and opinions to which the expert is expected to testify, and a summary of the grounds for each opinion.

Interrogatory No. 15
Describe in detail each communication between You and any non-party witness concerning this lawsuit or the events giving rise to it.

Interrogatory No. 16
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.

Interrogatory No. 17
Identify each document You intend to use as an exhibit at trial and state the purpose for which each will be offered.

Interrogatory No. 18
State whether You have entered into any settlement negotiations with Plaintiff regarding the claims in this action, and if so, provide the dates of such negotiations and the participants involved. (Do not disclose privileged settlement communications; identify existence only.)

Interrogatory No. 19
Describe all efforts made by You to comply with any statutory or contractual obligations implicated in Plaintiff’s claims.

Interrogatory No. 20
Identify any governmental or regulatory investigations, inquiries, or proceedings related to the subject matter of this litigation, including the agency involved, file number, and current status.

[Add Interrogatory Nos. 21-25, if needed, ensuring compliance with numerical limits.]

V. VERIFICATION
I, [AUTHORIZED REPRESENTATIVE/PARTY NAME], being duly sworn, depose and say that I am [position/title] of [DEFENDANT], that I have read the foregoing Answers to Interrogatories, and that the same are true and correct to the best of my knowledge, information, and belief.

[NAME]
[Title, if applicable]
[DEFENDANT NAME]

Subscribed and sworn to before me this ___ day of __, 20.

Notary Public
My Commission Expires: _______

VI. CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Plaintiff’s [First] Set of Interrogatories to Defendant was served upon counsel of record for Defendant via [method of service] on this ___ day of __, 20.

[ATTORNEY NAME], Esq.
[Law Firm]
[Address]
[Telephone]
[Email]
Counsel for Plaintiff

[// GUIDANCE:
1. Before service, counsel should:
• Confirm the current CPB limit on interrogatories and adjust the number accordingly.
• Review standing orders or individual judicial preferences that may affect discovery.
• Calendar the response deadline (default is typically 30 days from certification of service; add three days if service is by mail).
2. Privilege Logs: Prepare a log that itemizes each withheld document, lists authors/recipients, general subject matter, and the specific privilege asserted.
3. ESI Protocol: If the case involves significant ESI, consider serving a separate Request for ESI Protocol or including targeted ESI interrogatories.
4. Numerical Count: Remember that discrete subparts are counted as separate interrogatories if they are not logically or factually subsumed within the primary question.
5. Objections Strategy: Lodge objections narrowly; overbroad boilerplate objections are disfavored and risk waiver.
]