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

(Georgia State Court)

[// GUIDANCE: Replace bracketed text and delete guidance comments before service.]

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])

Pursuant to O.C.G.A. § 9-11-33 and Uniform Superior Court Rule 5.1, Plaintiff hereby propounds the following Interrogatories, to be answered fully, separately, and under oath within thirty (30) days after service hereof.

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.

[// GUIDANCE: Add or modify defined terms as needed for your matter.]

2. GENERAL INSTRUCTIONS

1. Answer Each Interrogatory Completely. Responses must be in writing, under oath, signed by the person making them, and served within 30 days of service of these Interrogatories. O.C.G.A. § 9-11-33(a)(2).
2. Numbering & Limits. Without prior court order, a party may serve no more than fifty (50) interrogatories, including discrete sub-parts. Uniform Superior Court Rule 5.1. [// GUIDANCE: Current count below is [##]; ensure compliance.]
3. Duty to Supplement. If You obtain additional responsive information, promptly supplement in accordance with O.C.G.A. § 9-11-26(e).
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.”
7. Continuing Nature. These Interrogatories are continuing, and You must supplement Your responses as additional information becomes available.

3. INTERROGATORIES

[// GUIDANCE: Tailor substance, remove or add interrogatories, and ensure total does not exceed 50 including sub-parts.]

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.]

4. VERIFICATION

STATE OF GEORGIA )
COUNTY OF __ )

Under penalty of perjury, the undersigned being duly sworn, deposes and states that he/she has read the foregoing responses to Interrogatories and that the responses are true and correct to the best of his/her knowledge, information, and belief.

[NAME OF RESPONDING PARTY]
[Title (if applicable)]

Subscribed and sworn before me
this ___ day of ____, 20__.

Notary Public, State of Georgia
My Commission Expires: ____

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]

[// GUIDANCE:
1. Double-check local standing orders or county-specific rules for additional discovery limitations or mandatory language.
2. Consider adding “Definitions” for specific terms unique to your case (e.g., product names, project codes).
3. For electronically served discovery, attach a separate “Certificate of Service – Electronic” if required.
4. Keep a Word or PDF version with line numbering for ease of objecting/answering.]