IN THE CIRCUIT COURT OF THE [__] JUDICIAL CIRCUIT

IN AND FOR [___] COUNTY, FLORIDA

[PLAINTIFF NAME],
  Plaintiff,

v.

[DEFENDANT NAME],
  Defendant.

Case No.: [_]
Division: [_]

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

[// GUIDANCE: This template is drafted under Fla. R. Civ. P. 1.340 and 1.280. Adapt the caption to match the style of the assigned division. Do not exceed 30 interrogatories, including discrete sub-parts, without prior stipulation or court order.]

I. INTRODUCTORY STATEMENT

Plaintiff, pursuant to Florida Rules of Civil Procedure 1.280 and 1.340, propounds the following Interrogatories to Defendant [DEFENDANT NAME] (“Defendant”). Defendant shall answer each Interrogatory separately, fully, under oath, and in writing within thirty (30) days of service hereof (or forty-five (45) days if these Interrogatories accompany initial service of process), serving the verified answers upon the undersigned counsel at the address below.

II. DEFINITIONS

For purposes of these Interrogatories, the following terms shall have the meanings set forth below:

1. “Action” means the above-captioned lawsuit and any related claims, defenses, counterclaims, or third-party claims.
2. “Communication” means any oral, written, or electronic transmission of information of any kind, including but not limited to conversations, correspondence, emails, text messages, and social-media posts.
3. “Document” is used in the broadest sense permitted by Fla. R. Civ. P. 1.350 and includes electronically stored information (“ESI”).
4. “Identify” or “Identification” when used:
   a. With respect to a person—state the person’s full name, last known address, telephone number, and relationship to the parties.
   b. With respect to a document—state the title, date, author, recipients, type (e.g., email, letter), subject matter, and present custodian.
   c. With respect to a communication—state the date, parties to the communication, medium, and substance.
5. “Person” means any natural individual, corporation, partnership, limited liability company, association, trust, governmental entity, or other legal entity.

[// GUIDANCE: Add or delete defined terms as appropriate to the underlying facts.]

III. INSTRUCTIONS

1. Answer each Interrogatory based on all information available to Defendant, including information in the possession, custody, or control of Defendant’s agents, representatives, and attorneys.
2. If Defendant withholds information based on any privilege or protection, set forth the nature of the privilege claimed and provide a privilege log in compliance with Fla. R. Civ. P. 1.280(b)(6).
3. If Defendant objects to any part of an Interrogatory, state the specific ground(s) for objection and answer the remainder of the Interrogatory.
4. These Interrogatories are deemed continuing; Defendant must promptly supplement or amend responses in accordance with Fla. R. Civ. P. 1.280(e) if it obtains additional responsive information.
5. Unless otherwise stated, the relevant time period is [RELEVANT PERIOD] through the present.

IV. GENERAL OBJECTIONS

Defendant may interpose the following general objections, each of which is incorporated into each specific response unless expressly stated otherwise:

A. Objection that an Interrogatory is vague, ambiguous, or overly broad.
B. Objection to the extent an Interrogatory seeks information protected by attorney–client privilege, work-product doctrine, or any other applicable privilege or immunity.
C. Objection to the extent an Interrogatory seeks information neither relevant to the subject matter of the Action nor proportionate to the needs of the case under Fla. R. Civ. P. 1.280(b)(1).

[// GUIDANCE: General objections should rarely be used standing-alone under current discovery standards. Tailor as necessary and provide specific objections with each response.]

V. INTERROGATORIES

1. Identify every person believed or known by Defendant to have personal knowledge of any facts alleged in the pleadings, and for each such person, state the specific topics of information.
2. Describe in detail the factual basis for each affirmative defense asserted in Defendant’s [Answer / other responsive pleading], including identification of supporting documents and witnesses.
3. State the name and qualifications of each expert witness Defendant intends to call at trial, the subject matter of each expert’s testimony, and the substance of all opinions to be offered.
4. List all insurance agreements under which any person carrying on an insurance business may be liable to satisfy part or all of a judgment that may be entered in this Action or to indemnify or reimburse payments made to satisfy the judgment.
5. Identify all communications between Defendant and Plaintiff concerning the subject matter of this Action, specifying the date, medium, participants, and substance.
6. State whether Defendant contends any documents have been lost, destroyed, or are otherwise unavailable, and for each such document, provide the title, date, author, subject, and circumstances of unavailability.
7. For each category of damages claimed by Defendant, set forth the amount, method of calculation, and all documents supporting the calculation.
8. Describe in detail all efforts undertaken by Defendant to preserve potentially relevant ESI once litigation became reasonably anticipated.
9. Identify every lawsuit, arbitration, or administrative proceeding involving Defendant within the last [X] years that relates to the same or similar subject matter as this Action.
10. State all facts supporting Defendant’s denial of Paragraph [__] of Plaintiff’s Complaint.
11. State all facts supporting Defendant’s denial of Paragraph [__] of Plaintiff’s Complaint.
12. State all facts supporting Defendant’s denial of Paragraph [__] of Plaintiff’s Complaint.
13. Identify all documents that support your responses to Interrogatories Nos. 1–12.
14. Identify all persons who assisted or supplied information used to prepare the answers to these Interrogatories.
15. State the basis for any contention by Defendant that Plaintiff failed to mitigate damages, including identification of supporting documents and witnesses.
16. Describe all internal policies, procedures, or guidelines relevant to the claims or defenses in this Action that were in effect during the relevant period.
17. Identify and describe any indemnity agreements, hold-harmless agreements, or similar contracts that may shift liability for the claims asserted in this Action.
18. State whether Defendant contends that any third party is partially or wholly responsible for the damages alleged, and if so, identify such third party and state the factual basis.
19. Describe in detail any settlement negotiations relating to the subject matter of this Action, including the dates of negotiations and parties involved.
20. Identify all social-media accounts maintained by Defendant that contain posts referring or relating to Plaintiff or the subject matter of this Action.
21. State the complete factual basis for Defendant’s position regarding the applicability of any statute of limitations or statute of repose.
22. Identify all industry standards, governmental regulations, or internal guidelines Defendant contends are relevant to the claims in this Action.
23. State in detail all facts supporting Defendant’s contention that Plaintiff’s alleged damages were caused by superseding or intervening causes.
24. Identify each request for admission served in this Action that Defendant has denied, and state the complete factual basis for each denial.
25. Describe any corrective or remedial actions taken by Defendant in response to the events giving rise to this Action.

[// GUIDANCE: Insert or revise interrogatories to fit the specific cause of action (e.g., contract, negligence, employment). Maintain compliance with the 30-interrogatory cap.]

VI. VERIFICATION

I, [AUTHORIZED REPRESENTATIVE NAME], being first duly sworn, depose and state that I am [TITLE] of Defendant [DEFENDANT NAME]; that I have read the foregoing Answers to Interrogatories and know the contents thereof; and that the answers are true and correct to the best of my knowledge, information, and belief.

[DEFENDANT NAME]

By: ____
Name: ____
Title: ____

State of _ )
County of _____ )

Sworn to (or affirmed) and subscribed before me this ___ day of _, 20_, by ____, who is personally known to me or who has produced ________ as identification.

Notary Public, State of _
My Commission Expires: _

VII. CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was served on this ___ day of ____, 20__, by [e-portal / U.S. Mail / email] upon:

[Opposing Counsel Name]
[Law Firm]
[Address]
[Email]

[ATTORNEY NAME], ESQ.
Florida Bar No. [__]
[LAW FIRM NAME]
[Address]
Telephone: []
Email: [___]

Attorney for Plaintiff

[// GUIDANCE:
1. Verification is required under Fla. R. Civ. P. 1.340(b).
2. Adapt notary block to account for Remote Online Notarization if used.
3. Update service method to comply with Fla. R. Jud. Admin. 2.516 (service by email is default).
4. Ensure interrogatory numbering does not exceed 30, including discrete sub-parts.
5. Review local administrative orders for additional formatting or font requirements.
]