State Court Discovery - Interrogatories - Iowa

[PROPOUNDING PARTY]'S INTERROGATORIES TO [RESPONDING PARTY]

IN THE IOWA DISTRICT COURT FOR [________________] COUNTY

Instructions

These interrogatories are served under Iowa R. Civ. P. 1.509 after satisfaction or lawful modification of the timing requirements in Rules 1.500, 1.505, and 1.507.

• Except in small claims, a party may serve interrogatories on another party.
• Unless stipulated or ordered for good cause, no more than thirty interrogatories, including discrete subparts, may be served on another party. A supreme-court-approved pattern interrogatory and its subparts count as one.
• Answers and objections are due within thirty days after service unless the court allows another time. Iowa Rule 1.509 does not create a forty-day defendant exception.
• Each interrogatory must be repeated immediately before its answer. Each nonobjected portion must be answered separately and fully in writing under oath. Objections must be specific; an unstated ground is waived unless the court excuses it for good cause.
• Answers are signed by the person making them; objections are signed by the objecting attorney. The request, response, or objection also must satisfy Rule 1.503(6)'s signature and reasonable-inquiry requirements.
• Discovery materials generally are served, not filed, under Rule 1.502 unless the court orders otherwise or a rule requires attachment to a motion.

Definitions

You / Responding Party: [DEFINE WITHOUT AUTOMATICALLY IMPUTING PRIVILEGED ATTORNEY KNOWLEDGE]

Document: Includes electronically stored information as provided in Rule 1.503(1)(a).

Relevant period: [__/__/____] through [__/__/____].

Interrogatories

1. Identify each person with knowledge of [SPECIFIC MATTER], stating the person's contact information and subject of knowledge.

2. State the facts supporting [CLAIM / DEFENSE / DENIAL] identified as [____________________________________________].

3. Identify each document supporting the response to Interrogatory No. 2.

4. State the specific amount and calculation of each category of damages claimed.

5. Identify insurance agreements potentially responsive under Iowa R. Civ. P. 1.503(2), without requesting privileged coverage advice.

6. Describe [TRANSACTION / EVENT] on [DATE], including participants and sequence.

7. Identify each communication concerning [SUBJECT], including date, participants, method, and general subject.

8. State the factual basis for each affirmative defense asserted in [PLEADING].

9. Identify any person or entity that may share responsibility for [EVENT OR LOSS] and state the supporting facts.

10. [CASE-SPECIFIC INTERROGATORY]

Add only case-specific interrogatories and count every discrete nonpattern subpart toward the thirty-interrogatory limit.

Privilege and Business Records

For information withheld as privileged or protected trial-preparation material, Rule 1.503(5)(a) requires an express claim and a description sufficient to assess the protection without revealing it. Rule 1.503(5)(b) governs notice and handling after privileged information is produced.

If Rule 1.509(3)'s business-record option is used, identify the records in enough detail for the requesting party to locate the answer as readily as the responding party and provide a reasonable opportunity to examine and copy them.

Signature and Service

Signature: [____________________________________________]

Printed name, address, telephone, and email: [____________________________________________]

Date: [__/__/____]

Service record or separate certificate: [____________________________________________]

Official Source

• Iowa Court Rules ch. 1 — https://www.legis.iowa.gov/docs/ACO/CR/LINC/07-31-2026.chapter.1.pdf