Delaware State Court Discovery Interrogatories
IN THE SUPERIOR COURT OF THE STATE OF DELAWARE
IN AND FOR [____________] COUNTY
| Party | Role |
|---|---|
| [PLAINTIFF NAME], | Plaintiff |
| v. | |
| [DEFENDANT NAME], | Defendant |
C.A. No.: [____________]
[PROPOUNDING PARTY]'S FIRST SET OF INTERROGATORIES TO [RESPONDING PARTY]
[PROPOUNDING PARTY] serves these interrogatories on [RESPONDING PARTY] under Del. Super. Ct. Civ. R. 33. Each interrogatory seeks nonprivileged information relevant to a claim or defense and proportional to the needs of this case under Rule 26(b)(1). Delete questions that do not fit the case and revise the remaining questions to identify the disputed events, issues, and period.
Responses. Serve separately numbered, full written answers under oath, or specific objections, within 30 days after service. A defendant may serve answers or objections within 45 days after service of the summons and complaint on that defendant. The Court may allow a shorter or longer period. Del. Super. Ct. Civ. R. 33(a), (b). Rule 6(e) adds three days to a period measured from service when service is by mail.
DEFINITIONS AND INSTRUCTIONS
- Action means the case identified in the caption. Incident means [DESCRIBE EVENT OR TRANSACTION]. Relevant Period means [START DATE] through [END DATE].
- Identify a person means provide the person's name, role in the Incident, and last known contact details, to the extent known after reasonable inquiry.
- Identify a document means provide its date, author, recipient, short description, and location or production identifier, to the extent known after reasonable inquiry.
- Answer each interrogatory separately and fully under oath. Restate each numbered interrogatory with its answer. An objection must state its grounds with specificity and answer any unobjectionable portion. Del. Super. Ct. Civ. R. 33(a), (b).
- If otherwise discoverable information is withheld on privilege or trial preparation grounds, expressly claim the protection and describe what was withheld without disclosing the protected information, so the other parties can assess the claim. Del. Super. Ct. Civ. R. 26(b)(7).
- Supplement or amend an answer when Rule 26(e)(1) or (2) requires it, or when a court order, agreement, or new request imposes that duty under Rule 26(e)(3). A complete response is not automatically subject to continuing supplementation.
- If an answer can be derived from business records and the burden of deriving it is substantially the same for both parties, the responding party may identify the records in enough detail to locate them and afford a reasonable opportunity to examine and copy them. Del. Super. Ct. Civ. R. 33(d).
INTERROGATORIES
Interrogatory No. 1
Identify the person or persons who supplied information used to prepare your answers, stating the subjects each addressed.
Answer or objection:
[____________________________________________________________]
[____________________________________________________________]
Interrogatory No. 2
Identify each person known to you to have firsthand knowledge of [SPECIFIC DISPUTED EVENT OR TRANSACTION], and state the subject of that knowledge.
Answer or objection:
[____________________________________________________________]
[____________________________________________________________]
Interrogatory No. 3
State the facts supporting your position on [IDENTIFY SPECIFIC CLAIM, DEFENSE, OR DISPUTED FACT], and identify the persons and nonprivileged documents supporting those facts.
Answer or objection:
[____________________________________________________________]
[____________________________________________________________]
Interrogatory No. 4
Describe your account of [SPECIFIC EVENT], including its date, location, people present, and actions you contend occurred.
Answer or objection:
[____________________________________________________________]
[____________________________________________________________]
Interrogatory No. 5
Identify communications between you and [NAMED PERSON] about [SPECIFIC SUBJECT] during the Relevant Period, stating the date, participants, medium, and general subject of each.
Answer or objection:
[____________________________________________________________]
[____________________________________________________________]
Interrogatory No. 6
If you contend that [IDENTIFY ALLEGED ACT OR OMISSION] did not occur, state the facts supporting that contention and identify the people with firsthand knowledge of those facts.
Answer or objection:
[____________________________________________________________]
[____________________________________________________________]
Interrogatory No. 7
If you claim damages arising from [SPECIFIC CLAIM], identify each category, amount, method of calculation, and documents supporting the calculation.
Answer or objection:
[____________________________________________________________]
[____________________________________________________________]
Interrogatory No. 8
Identify each insurance agreement that you contend may satisfy or reimburse payment of a judgment in this Action, stating the insurer, policy number, coverage period, and applicable limits. Del. Super. Ct. Civ. R. 26(b)(2).
Answer or objection:
[____________________________________________________________]
[____________________________________________________________]
Interrogatory No. 9
Identify each expert you expect to call at trial on [SPECIFIC ISSUE], the subject matter, the substance of expected facts and opinions, and a summary of the grounds for each opinion, subject to Rule 26(b)(4) and the case scheduling order.
Answer or objection:
[____________________________________________________________]
[____________________________________________________________]
Interrogatory No. 10
Identify nonprivileged records you contend support [SPECIFIC CLAIM OR DEFENSE], including their date, custodian, and production identifier if already produced.
Answer or objection:
[____________________________________________________________]
[____________________________________________________________]
Interrogatory No. 11
State whether any responsive record concerning [SPECIFIC SUBJECT] was lost or destroyed during [SPECIFIC PERIOD], and if so state the date, circumstances, and persons with knowledge, without disclosing protected communications.
Answer or objection:
[____________________________________________________________]
[____________________________________________________________]
Interrogatory No. 12
[ADD A FACT SPECIFIC QUESTION WITHIN RULE 26(b)(1)'S SCOPE.]
Answer or objection:
[____________________________________________________________]
[____________________________________________________________]
CERTIFICATE OF SERVICE
I certify that on [DATE], I served this set of interrogatories on [COUNSEL OR PARTY NAME] by [AUTHORIZED METHOD OF SERVICE] at [ADDRESS OR OTHER SERVICE DESTINATION], under Del. Super. Ct. Civ. R. 5(b).
Signature: ___________________________
[ATTORNEY NAME], Delaware Bar No. [______]
Attorney for [PROPOUNDING PARTY]
[ADDRESS, PHONE, EMAIL]
SEPARATE NOTICE OF SERVICE (FILE THIS NOTICE; DO NOT FILE THE INTERROGATORIES)
| Party | Role |
|---|---|
| [PLAINTIFF NAME], | Plaintiff |
| v. | |
| [DEFENDANT NAME], | Defendant |
In the Superior Court of the State of Delaware, in and for [COUNTY] County
C.A. No.: [____________]
NOTICE OF SERVICE OF INTERROGATORIES
Counsel for [PROPOUNDING PARTY] certifies that on [DATE], [PROPOUNDING PARTY]'s [FIRST/SECOND] Set of Interrogatories to [RESPONDING PARTY] was served on [COUNSEL OR PARTY NAMES] by [MANNER OF SERVICE]. This Notice states the form of discovery served and its date and manner of service under Del. Super. Ct. Civ. R. 5(d)(1).
Date: [DATE]
Signature: ___________________________
[ATTORNEY NAME], Delaware Bar No. [______]
Attorney for [PROPOUNDING PARTY]
SOURCES AND REFERENCES
- Delaware Superior Court Civil Rules, current official compilation: Rules 5(b), 5(d)(1), 6(e), 26(b)(1), (b)(2), (b)(4), (b)(7), 26(e), and 33(a)-(d).
About this template
- Last updated
- October 4, 2026
- Citations checked
- October 4, 2026
- Jurisdiction
- Delaware
- Category
- Litigation & Court Documents
Legal authority
- Del. Super. Ct. Civ. R. 33(a)-(d) (Interrogatories to Parties)
- Del. Super. Ct. Civ. R. 26(b)(1), (b)(4), (b)(7), (e) (Scope, Experts, Privilege, and Supplementation)
- Del. Super. Ct. Civ. R. 5(b), (d)(1) (Service and Notice of Service)
- Del. Super. Ct. Civ. R. 6(e) (Mail Service Time)
These are the filings that drive a lawsuit through the system: complaints, answers, motions, briefs, discovery requests and responses, and post-judgment papers. Each has its own format requirements under federal and state procedural rules, and each has a deadline that cannot be missed without consequences. Clean, procedurally correct filings move a case forward; sloppy ones invite motions to strike, amended responses, and avoidable delays.
Not legal advice
This template is provided for informational purposes. We recommend having an attorney review any legal document before signing, especially for high-value or complex matters.
Checked against the law it cites
A reviewer verified this template's legal citations against the official source on October 4, 2026.
Del. Super. Ct. Civ. R. 33(a), (b) (checked October 4, 2026): "Each interrogatory shall be restated as numbered and shall be answered separately and fully in writing under oath, unless it is objected to, in which event the reasons for objection shall be stated in lieu of an answer."
Del. Super. Ct. Civ. R. 33(d) (checked October 4, 2026): "A specification shall be in sufficient detail to permit the interrogating party to locate and to identify, as readily as can the party served, the records from which the answer may be ascertained."
Del. Super. Ct. Civ. R. 33(b)(3) (checked October 4, 2026): "The party upon whom the interrogatories have been served shall serve a copy of the answers, and objections if any, within 30 days after the service of the interrogatories, except that a defendant may serve answers or objections within 45 days after service of the summons and complaint upon that defendant."
Del. Super. Ct. Civ. R. 26(b)(1) (checked October 4, 2026): "Parties may obtain discovery regarding any non-privileged matter that is relevant to any party’s claim or defense and proportional to the needs of the case."
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