IN THE SUPERIOR COURT OF THE DISTRICT OF COLUMBIA
Civil Division
[PLAINTIFF NAME], )
)
Plaintiff, )
)
v. ) Civil Action No. [____]
)
[DEFENDANT NAME], )
)
Defendant. )
PLAINTIFF’S FIRST SET OF INTERROGATORIES
TO DEFENDANT [DEFENDANT NAME]
[// GUIDANCE: Title may be reversed if propounded by Defendant. Replace
“FIRST” with “SECOND,” “THIRD,” etc. when serving subsequent sets.]
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TABLE OF CONTENTS
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I. Preliminary Statement..................................... 2
II. Definitions............................................... 2
III. General Instructions...................................... 4
IV. Interrogatories Nos. 1-[__]............................... 7
V. Verification............................................. 13
VI. Certificate of Service................................... 14
I. PRELIMINARY STATEMENT
Pursuant to D.C. Super. Ct. R. Civ. P. 26 and 33, Plaintiff propounds the
following Interrogatories to be answered fully, separately, and under oath
by Defendant [DEFENDANT NAME] within the time prescribed by Rule 33(b)(2)—
i.e., within 30 days after service hereof (or 45 days after service of the
Complaint if these Interrogatories accompany initial service of process).
These Interrogatories are continuing in nature; Defendant must seasonably
supplement its responses in accordance with Rule 26(e).
II. DEFINITIONS
For purposes of these Interrogatories, the following terms shall have the
meanings set forth below. Undefined terms shall be given their ordinary
meaning as used in the D.C. Superior Court Rules of Civil Procedure.
-
“Action” means the above-captioned civil action and any related
proceedings, claims, counterclaims, or third-party claims. -
“Communication” means any oral, written, electronic, or other transfer
of information, including but not limited to correspondence, e-mail,
text message, social-media post, telephone call, meeting, or
videoconference. -
“Concerning” (and “relating to,” “regarding,” “reflecting,” or any
variant thereof) means directly or indirectly mentioning, describing,
constituting, summarizing, evidencing, or otherwise involving. -
“Document” is defined to be synonymous in meaning and scope with the
usage of that term in D.C. Super. Ct. R. Civ. P. 34(a) and includes all
tangible things and electronically stored information (“ESI”), drafts,
and non-identical copies. -
“Identify” or “state the identity of” means:
a. With respect to a natural person: full name, last known address,
telephone number, e-mail address, and employer and position at the
time relevant to the request;
b. With respect to an entity: full legal name, principal place of
business, and nature of the entity;
c. With respect to a document: title, date, author(s), recipient(s),
type of document, Bates number (if any), and present custodian.
-
“Person” means any natural person or legal entity.
-
“Plaintiff,” “Defendant,” “You,” and “Your” refer to the respective
parties and their present and former officers, directors, employees,
agents, attorneys, and all other persons acting or purporting to act on
their behalf.
[// GUIDANCE: Add, delete, or adjust definitions as necessary for the
specific case.]
III. GENERAL INSTRUCTIONS
A. Rule Compliance
These Interrogatories are subject to the limitations of D.C. Super.
Ct. R. Civ. P. 33(a)(1), which caps interrogatories (inclusive of
discrete subparts) at forty (40) unless otherwise stipulated or
ordered. The propounding party believes that the number served herein
complies with that limit.
B. Answering Each Interrogatory
1. Answer each Interrogatory separately and fully in writing under
oath.
2. Precede each answer with the corresponding Interrogatory.
3. If You object to an Interrogatory or any portion thereof, state
with specificity the grounds for objection and answer all parts not
objected to.
C. Privilege and Work-Product
If You withhold information based on a claim of privilege or
protection, expressly make the claim and provide a privilege log that
complies with Rule 26(b)(5)(A) sufficient to enable Plaintiff to
assess the applicability of the asserted privilege.
D. Time Period
Unless otherwise specified, each Interrogatory seeks information for
the period [START DATE] through the present.
E. Continuing Duty
These Interrogatories are deemed continuing. If You obtain additional
responsive information after serving answers, You must promptly
supplement Your responses under Rule 26(e).
F. Electronically Stored Information
If responsive information resides in ESI, identify the system,
database, or medium in which such ESI is located and describe the
search methodology used.
G. Constructions
1. The singular includes the plural and vice versa.
2. The masculine, feminine, and neuter genders include each other.
3. “And” and “or” shall be construed conjunctively or disjunctively as
necessary to bring within the scope of the request any information
that might otherwise be outside its scope.
[// GUIDANCE: Consider adding ESI protocol cross-references if a separate
ESI order exists.]
IV. INTERROGATORIES
Interrogatory No. 1
Identify all persons who participated in preparing the answers to these
Interrogatories.
Interrogatory No. 2
Identify every person known or believed by You to have knowledge of any
facts alleged in the Complaint or any defenses asserted in Your Answer.
Interrogatory No. 3
State the factual bases for each affirmative defense pled in Your Answer,
including identification of all documents and persons with knowledge.
Interrogatory No. 4
Describe in detail all Communications between You and Plaintiff concerning
the subject matter of this Action.
Interrogatory No. 5
Identify all documents that You contend support Your defenses or refute
Plaintiff’s claims.
Interrogatory No. 6
State the name, address, and qualifications of each expert You expect to
call at trial and summarize the substance of each expert’s anticipated
testimony.
Interrogatory No. 7
Provide a detailed description of any insurance agreement under which an
insurance business may be liable to satisfy all or part of a judgment
entered in this Action or to indemnify or reimburse for payments made to
satisfy the judgment.
Interrogatory No. 8
Describe all efforts undertaken by You to preserve documents and ESI
potentially relevant to this Action, including the litigation-hold process
used.
Interrogatory No. 9
Identify and quantify each category of damages You contend Plaintiff has
caused You, including the methodology used to calculate each category.
Interrogatory No. 10
State the factual basis for any contention that Plaintiff failed to
mitigate damages.
Interrogatory No. 11
Identify all prior complaints, claims, or lawsuits within the past five
(5) years alleging substantially similar conduct by You.
Interrogatory No. 12
Identify all persons involved in the events giving rise to Plaintiff’s
claims and describe their respective roles.
Interrogatory No. 13
Describe in detail all policies, procedures, or training materials in
effect during the relevant period that relate to the conduct alleged in
the Complaint.
Interrogatory No. 14
State all facts upon which You rely to dispute any element of Plaintiff’s
claimed damages.
Interrogatory No. 15
Identify and describe any efforts at settlement, compromise, or ADR that
have occurred between the parties concerning the claims at issue.
Interrogatory No. 16
State the factual basis for any contention that any third party is wholly
or partially responsible for the injuries or damages alleged by Plaintiff.
Interrogatory No. 17
Identify all individuals You expect to testify at trial (other than
experts identified in Interrogatory 6) and provide a summary of each
individual’s expected testimony.
Interrogatory No. 18
Describe any document retention or destruction policies applicable during
the relevant time period and identify any documents destroyed pursuant to
such policies that would have been responsive to these Interrogatories.
Interrogatory No. 19
State whether You contend that any of Plaintiff’s claims are barred by the
statute of limitations and identify the specific limitation period
asserted and the facts supporting that contention.
Interrogatory No. 20
Identify all databases, servers, cloud services, or other electronic
repositories that may contain ESI relevant to this Action, specifying the
type of data stored, custodians, and relevant date ranges.
[// GUIDANCE: The template provides 20 Interrogatories, leaving space for
up to 40 under Rule 33(a)(1). Insert or delete as necessary, ensuring the
total number—including subparts—does not exceed the limit without leave of
court or stipulation.]
V. VERIFICATION
I, _______, being duly sworn, state that I am
authorized to make this Verification on behalf of Defendant
[DEFENDANT NAME]; that I have read the foregoing Answers to
Interrogatories; and that the matters stated therein are true and correct
to the best of my knowledge, information, and belief.
Date: ____ _____
[NAME]
[TITLE/POSITION]
Subscribed and sworn to before me on this ___ day of _, 20.
Notary Public
My commission expires: ____
VI. CERTIFICATE OF SERVICE
I hereby certify that on this ___ day of _, 20, a true and
correct copy of the foregoing Plaintiff’s First Set of Interrogatories to
Defendant [DEFENDANT NAME] was served via
☐ CaseFileXpress e-filing system
☐ Hand delivery
☐ U.S. Mail, postage prepaid
☐ E-mail (by agreement of counsel)
upon:
[OPPOSING COUNSEL NAME]
[LAW FIRM]
[ADDRESS]
[E-MAIL]
[ATTORNEY NAME]
Counsel for Plaintiff
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END OF DOCUMENT
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[// GUIDANCE:
1. Review all rule citations and adapt if the D.C. Superior Court amends its Rules.
2. Consider local Standing Orders or Case Management Plans that may alter default deadlines.
3. Insert additional interrogatories (up to 40 total) tailored to the specific claims or defenses.
4. Remove the notary block if verification under 28 U.S.C. § 1746 (unsworn declaration) is acceptable in your jurisdiction.
5. Ensure that electronic service complies with any consent requirements under Rule 5(b)(2)(E).]