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. O.C.G.A. § 9-11-33(a) limits interrogatories to 50 including subparts per responding party without court leave on the statutory showing. Answers or objections are due within 30 days after service; a defendant may respond within 45 days after service of the summons and complaint, and the court may allow a shorter or longer time. Before service, enter the cumulative count and subpart method [DETAILS], any court order or leave [DETAILS], service date and method [DETAILS], and calculated response date [DATE].

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” includes the writings, photographs, and other data compilations described in O.C.G.A. § 9-11-34(a), including responsive information stored electronically when it fits those categories.

“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 responding party and information available to that party through its authorized personnel, subject to applicable privileges and the discovery scope.

2. GENERAL INSTRUCTIONS

Supplementation. O.C.G.A. § 9-11-26(e) requires later supplementation for specified witness and expert identity information, correction of a response known to have been wrong when made, and correction when an unchanged answer would knowingly conceal the truth. An order, party agreement, or new request before trial may impose another duty. Apply that section and any controlling order or agreement; these interrogatories do not create a broader continuing duty.

4. Objections & Privilege Claims. State each specific objection and its grounds. If withholding information on privilege grounds, identify the privilege and provide the information required by the governing law or court order without disclosing the protected substance.
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 interrogatories only within the 50-count limit, including subparts, or as the court permits under O.C.G.A. § 9-11-33(a).]

RESPONSE VERIFICATION CONTROL

O.C.G.A. § 9-11-33(a) requires each answer to be written under oath and signed by the person making it; the attorney signs objections. Before answers are served, confirm the authorized signer, oath and jurat, and any governing order: [DETAILS].

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 upon the attorney of record, unless the court ordered service on the party, by [hand delivery / mail to the last known address / statutory electronic service under O.C.G.A. § 9-11-5(b), (f)] upon:

For statutory electronic service, I sent a PDF to every email address supplied under § 9-11-5(f) with “STATUTORY ELECTRONIC SERVICE” in the subject line: [EMAIL ADDRESSES / CONSENT BASIS].

[Name & Address of Counsel of Record]

This ___ day of __________, 20__.

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