State Court Discovery - Interrogatories - Georgia

[PLAINTIFF’S/DEFENDANT’S] FIRST SET OF INTERROGATORIES

(Georgia State Court)

DOCUMENT HEADER

IN THE SUPERIOR COURT OF [___] COUNTY
STATE OF GEORGIA

PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT
(Date of Service: [MM/DD/YYYY])

Count and deadline control. Before service, enter the governing rule or order [CITATION], cumulative interrogatory count and subpart method [DETAILS], leave, stipulation, or local-limit status [DETAILS], service date and method [DETAILS], response period [DETAILS], and calculated response date [DATE]. This form states no default number or period.

TABLE OF CONTENTS

1. Definitions & Rules of Construction
2. General Instructions
3. Interrogatories (Nos. 1-☐)
4. Verification
5. Certificate of Service

1. DEFINITIONS & RULES OF CONSTRUCTION

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

“Action” means the above-captioned lawsuit, including any related appeals.

“Communication” means any oral or written statement, dialogue, conversation, discussion, e-mail, text message, letter, memorandum, or other transfer of information.

“Document” has the broadest meaning under O.C.G.A. § 9-11-34 and includes electronically stored information (“ESI”).

“Identify” (with respect to a person) means to state the person’s full name, last known address and telephone number, and relationship to any party.

“Party,” “You,” or “Your” refers to the party to whom these Interrogatories are directed, including all agents, employees, representatives, predecessors, successors, and attorneys.

2. GENERAL INSTRUCTIONS

Supplementation control. Apply only the duty supplied by the current governing rule, order, or agreement: [CITATION / TERMS / NONE IDENTIFIED]. Do not label these interrogatories “continuing” or demand supplementation beyond that authority.

4. Objections & Privilege Claims. State each specific objection and the grounds therefore. If information is withheld on the basis of privilege, produce a privilege log identifying the nature of the material, date, author, recipient, and privilege asserted.
5. Time Period. Unless otherwise indicated, these Interrogatories seek information from [INSERT START DATE] through the present.
6. Constructions. Singular includes plural, the masculine includes feminine and vice-versa, and the term “including” means “including without limitation.”

3. INTERROGATORIES

Interrogatory No. 1

Identify every person with knowledge of any fact alleged in the pleadings, and for each such person describe the subject matter of his or her knowledge.

Interrogatory No. 2

State the name, address, and telephone number of each expert You expect to call at trial, and for each expert provide:
a. Field of expertise;
b. Subject matter of expected testimony;
c. Substance of facts and opinions to which the expert is expected to testify; and
d. Summary of the grounds for each opinion.

Interrogatory No. 3

Describe in detail the factual basis for each affirmative defense asserted in Your [Answer/Responsive Pleading].

Interrogatory No. 4

For each document responsive to Plaintiff’s First Request for Production, identify:
a. Bates range or unique identifier;
b. Custodian; and
c. The interrogatory or request to which it is responsive.

Interrogatory No. 5

Itemize all damages You claim in this Action, including:
a. Type of damage (e.g., lost profits, medical expenses, property damage);
b. Amount;
c. Method of calculation; and
d. All documents supporting each item.

Interrogatory No. 6

Identify any insurance agreement under which an insurer may be liable to satisfy part or all of any judgment against You or to indemnify or reimburse for payments made, and state the limits of coverage.

Interrogatory No. 7

Describe all efforts You made to preserve documents and ESI relevant to this Action, including the dates of any litigation holds issued and the categories of data preserved.

Interrogatory No. 8

Identify every Communication between You and [OPPOSING PARTY] concerning the matters alleged in the Complaint, stating the date, participants, and a summary of the content.

Interrogatory No. 9

State whether You have been convicted of any felony or a crime involving dishonesty or false statement within the past ten (10) years, and if so, identify the jurisdiction, case number, date of conviction, and sentence imposed.

Interrogatory No. 10

List any witness statements (recorded or written) in Your possession, custody, or control regarding this Action, identifying for each statement:
a. Witness name;
b. Date of statement;
c. Form (audio, video, written, etc.); and
d. Whether it has been produced.

[Add additional interrogatories as necessary, not to exceed 50 total.]

RESPONSE VERIFICATION CONTROL

The propounding paper does not prescribe a verification method. Before answers are served, enter the current rule or order, authorized signer, oath or declaration text, and any jurat requirement: [DETAILS]. Delete unused oath, declaration, and notary options.

5. CERTIFICATE OF SERVICE

I hereby certify that I have this day served a true and correct copy of the foregoing [PLAINTIFF’S/DEFENDANT’S] First Set of Interrogatories by [hand delivery / statutory electronic service / U.S. Mail] upon:

[Name & Address of Counsel of Record]

This ___ day of __________, 20__.

____________________________________
[COUNSEL NAME]
[Georgia Bar No. _____]
[Law Firm]
[Address]
[Phone] | [Email]