State Court Discovery - Interrogatories

IN THE SUPERIOR COURT OF THE DISTRICT OF COLUMBIA

Civil Division

Civil Action No.: [________________________________]

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

I. CURRENT-RULE AND CASE-ORDER CONTROL

Complete before drafting or service:

Counsel / reviewer: [________________________________]

Review date: [__/__/____]

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 selected by counsel for this case.

1. “Action” means the above-captioned civil action and any related
   proceedings, claims, counterclaims, or third-party claims.

2. “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.

3. “Concerning” (and “relating to,” “regarding,” “reflecting,” or any
   variant thereof) means directly or indirectly mentioning, describing,
   constituting, summarizing, evidencing, or otherwise involving.

4. “Document” means [CASE-SPECIFIC DEFINITION CONSISTENT WITH CURRENT LAW
   AND THE DISCOVERY ORDER].

5. “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.

6. “Person” means any natural person or legal entity.

7. “You” and “Your” mean [RESPONDING PARTY]. Do not expand this definition
   to attorneys, former personnel, affiliates, or agents unless current law
   and the facts support that scope.

III. INSTRUCTIONS — COMPLETE FROM CURRENT AUTHORITY

Delete this section and substitute case-ready instructions reviewed against
the control table. At minimum, address:

• how each interrogatory must be answered or objected to;
• treatment of unobjectionable portions;
• the selected response deadline;
• the selected privilege or protection procedure;
• any supplementation obligation;
• the relevant time period;
• ESI terminology that matches the case and the responding party's systems;
• confidentiality, personal-information, and protective-order restrictions; and
• the current signature, verification, filing, and service procedure.

Avoid blanket constructions that automatically broaden “and,” “or,” “all,”
“each,” “concerning,” or a party definition beyond the authorized scope.

IV. CANDIDATE INTERROGATORY BANK

Select, narrow, renumber, and link each question to a pleaded claim, defense,
damages issue, or other authorized subject. Delete every unused question.
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.

V. RESPONSE-EXECUTION PLANNING

Do not serve a responding-party verification with the propounding paper.
For later answers, counsel must use the current signature, oath or
verification, representative-capacity, and notarization requirements entered
in the control table.

VI. SERVICE RECORD

Complete from the current service rule, the case docket, and any agreement or
order:

Attorney signature block required on served paper:

[ATTORNEY NAME]

[FIRM]

[BAR NUMBER]

[ADDRESS]

[EMAIL / PHONE]