[COURT NAME], [COUNTY], STATE OF IDAHO

[CASE NO. ____]

[PLAINTIFF NAME(S)],
  Plaintiff(s),

v.

[DEFENDANT NAME(S)],
  Defendant(s).

PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT

(Idaho R. Civ. P. 33; 26(b)(5)(A))

[// GUIDANCE: Replace “Plaintiff” and “Defendant” with “Propounding Party” and “Responding Party” if the roles are reversed.]

TABLE OF CONTENTS

1. Document Header
2. Preliminary Statement
3. Definitions
4. General Instructions
5. General Objections
6. Specific Interrogatories (Nos. 1-[__])
7. Verification
8. Certificate of Service

1. DOCUMENT HEADER

Date Served: [DATE]
Propounding Party: [PLAINTIFF NAME(S)] (“Plaintiff”)
Responding Party: [DEFENDANT NAME(S)] (“Defendant”)
Set Number: First

2. PRELIMINARY STATEMENT

Pursuant to Idaho Rule of Civil Procedure 33, Plaintiff hereby propounds the following Interrogatories to be answered fully, separately, and in writing under oath by Defendant within the time prescribed by the Idaho Rules of Civil Procedure.

3. DEFINITIONS

For purposes of these Interrogatories, the following terms shall have the meanings set forth below. Each defined term is capitalized and used consistently throughout.

1. “Action” means the above-captioned lawsuit.
2. “Communication” means any transmission of information, whether oral, written, electronic, or otherwise.
3. “Concerning” or “Relating to” means referring to, describing, evidencing, constituting, or pertaining to.
4. “Document” has the broadest meaning allowed under Idaho R. Civ. P. 34(a) and includes electronically stored information (“ESI”).
5. “Identify” when used with reference to:
   a. A person: provide full name, last known address, telephone number, and relationship to any Party.
   b. A document: state its title, date, author, recipient(s), type (e-mail, memo, etc.), and present custodian.
6. “Person” means any natural person or legal entity.
7. “You,” “Your,” or “Defendant” refers to the Responding Party and all agents, employees, representatives, and attorneys acting or purporting to act on its behalf.

4. GENERAL INSTRUCTIONS

1. Answer each Interrogatory separately and fully, in writing and under oath, within 30 days after service (or 45 days if these Interrogatories accompany service of the Summons and Complaint). See Idaho R. Civ. P. 33(b)(2).
2. If You object to an Interrogatory, state the specific ground(s) and answer the remainder to the extent not objectionable. General objections are disfavored.
3. Each Interrogatory is deemed to be continuing. Promptly supplement or correct Your answers in accordance with Idaho R. Civ. P. 26(e).
4. If You withhold information based upon any claim of privilege or protection, produce a privilege log that complies with Idaho R. Civ. P. 26(b)(5)(A), identifying the nature of the privilege and sufficient detail to enable assessment of the claim without revealing privileged information.
5. Unless otherwise agreed or ordered, You may not serve more than 40 interrogatories, including discrete subparts. See Idaho R. Civ. P. 33(a)(1). These Interrogatories are counted toward that limit.
6. Furnish all responsive information in Your possession, custody, or control, including information held by Your current or former agents, employees, accountants, and attorneys (except privileged communications).
7. Where knowledge, information, or documents are requested, such request includes knowledge, information, or documents reasonably available to You.
8. When the name or identity of a person is requested, please also provide all known aliases.

[// GUIDANCE: Parties may stipulate to additional interrogatories under Rule 33(a)(1) or seek court leave.]

5. GENERAL OBJECTIONS

Plaintiff incorporates the following General Objections, which apply to each Interrogatory and are not waived by any specific response:

1. Plaintiff objects to any Interrogatory to the extent it seeks information protected by the attorney-client privilege, work-product doctrine, or any other applicable privilege or immunity.
2. Plaintiff objects to any Interrogatory that is vague, ambiguous, overly broad, unduly burdensome, or not proportional to the needs of the case as required by Idaho R. Civ. P. 26(b)(1).
3. Plaintiff objects to the extent any Interrogatory seeks confidential or proprietary information absent an appropriate protective order.

[// GUIDANCE: Tailor General Objections; avoid boilerplate that lacks specificity.]

6. SPECIFIC INTERROGATORIES

Answer each Interrogatory in the space provided or on separate sheets reproducing each question in full.

Interrogatory No. 1

State all facts supporting Your denial of any material allegation in the Complaint.

Interrogatory No. 2

Identify every person with knowledge of facts Concerning the claims or defenses in this Action, stating the subject matter of each person’s knowledge.

Interrogatory No. 3

Describe in detail each Communication between You and [ANY OTHER PARTY / NON-PARTY] Concerning the matters alleged in the Complaint.

Interrogatory No. 4

Identify and describe all Documents You contend support Your affirmative defenses, including the Bates range for each Document.

Interrogatory No. 5

State the factual basis for each element of damages You allege Plaintiff caused.

Interrogatory No. 6

Identify all insurance agreements under which any insurer may be liable to satisfy part or all of a judgment in this Action or to indemnify or reimburse You.

Interrogatory No. 7

Describe with particularity every effort You made to preserve Documents and ESI relevant to this Action, including the dates and methods of any litigation hold.

Interrogatory No. 8

Identify any expert witness You expect to call at trial, stating the subject matter and a brief summary of the opinions to be expressed.

Interrogatory No. 9

State whether You have ever been a party to any prior litigation Concerning [RELEVANT SUBJECT MATTER], and for each such litigation, provide the case caption, court, case number, and ultimate disposition.

Interrogatory No. 10

For each affirmative defense based on statute, regulation, or common law, identify the specific legal authority and describe the facts supporting its application to this Action.

[// GUIDANCE: Add or delete Interrogatories up to the Rule 33 limit, being mindful of discrete subparts.]

7. VERIFICATION

I, [NAME], declare under penalty of perjury pursuant to Idaho Code § 9-1404 that I am authorized to answer these Interrogatories on behalf of Defendant and that the foregoing answers are true and correct to the best of my knowledge, information, and belief.

Date: _______

[NAME]
[Title/Position, if applicable]

8. CERTIFICATE OF SERVICE

I certify that on the _ day of _ 20__, I served the foregoing Plaintiff’s First Set of Interrogatories to Defendant by:

☐ Hand Delivery
☐ U.S. Mail, postage prepaid
☐ Overnight Delivery
☐ E-mail (by agreement of counsel)
☐ Idaho Court E-File System

to:

[OPPOSING COUNSEL NAME]
[LAW FIRM]
[ADDRESS]
[EMAIL]

[ATTORNEY NAME]
Attorney for Plaintiff

[// GUIDANCE:
1. Always review local rules and scheduling orders for case-specific limitations or deadlines superseding default rules.
2. Confirm service method complies with Idaho R. Civ. P. 5.
3. Consider entering a stipulated protective order before seeking highly confidential information.]