Idaho State Court Discovery Interrogatories

IN THE DISTRICT COURT OF THE [____________] JUDICIAL DISTRICT OF THE STATE OF IDAHO, IN AND FOR THE COUNTY OF [____________]

CASE NO.: [____________]

[PROPOUNDING PARTY]'S FIRST SET OF INTERROGATORIES TO [RESPONDING PARTY]

TO: [RESPONDING PARTY], through [COUNSEL NAME, IF REPRESENTED].

Under Idaho R. Civ. P. 33, [PROPOUNDING PARTY] serves these interrogatories on [RESPONDING PARTY]. Answer each interrogatory separately and fully in writing under oath to the extent it is not objected to. Set forth each interrogatory before its answer or objection. The responding person must sign the answers, and the attorney who objects must sign the objections. State objection grounds with specificity.

Response date: Answers and objections are ordinarily due 30 days after service. A shorter or longer time may be stipulated under Rule 29 or ordered by the court. An extension that interferes with the trial date or requires approval under another order needs court approval. The calculated response date is [__/__/____], subject to any applicable order or stipulation.

Limit and scope: Unless the court allows a specific additional number for good cause or the parties stipulate otherwise, a party may serve no more than 40 interrogatories including all discrete subparts. Count this set with prior interrogatories served by the same party. These questions seek nonprivileged matter relevant to a claim or defense, subject to Rule 26(b)(1)'s limits. Delete or narrow questions that do not fit this action.

Nonfiling and notice: Serve these interrogatories; do not file them or the answers with the court. File a separate notice stating when and on whom they were served. The propounding party must retain the original interrogatories, answers, and proof of service for one year after final disposition and expiration of the appeal period, unless the court orders longer retention. Idaho R. Civ. P. 33(e).

Definitions

1. You means [RESPONDING PARTY] and information reasonably available to that party. It does not demand disclosure of privileged communications.
2. Action means the case identified above.
3. Relevant period means [__/__/____] through [__/__/____], unless a question states another period.
4. Document includes writings, records, and electronically stored information. When a question asks You to identify a document, provide its date, type, author, recipient, and custodian if known.

Interrogatories

Interrogatory No. 1. Identify each person with knowledge of [SPECIFIED CLAIM OR DEFENSE] and state the subject of that person's knowledge.

Interrogatory No. 2. State the facts on which You base Your denial of paragraph [____] of the [COMPLAINT / OTHER PLEADING].

Interrogatory No. 3. Identify the documents on which You rely for the answer to Interrogatory No. 2.

Interrogatory No. 4. Describe each communication between You and [PERSON OR ENTITY] about [DEFINED SUBJECT] during the Relevant Period, stating its date, participants, and substance, excluding privileged communications.

Interrogatory No. 5. State the factual basis for [IDENTIFIED AFFIRMATIVE DEFENSE OR CLAIM], including the conduct and dates on which You rely.

Interrogatory No. 6. State the amount and method of calculation of [SPECIFIED CATEGORY OF DAMAGES] that You claim in this Action.

Interrogatory No. 7. Identify any insurance agreement under which an insurer may be liable to satisfy all or part of a judgment in this Action or to indemnify or reimburse payment of such a judgment, stating the insurer and policy number if known.

Interrogatory No. 8. Identify each expert witness You expect to call at trial concerning [SUBJECT], subject to the disclosure limits and protections of Idaho R. Civ. P. 26(b)(4).

Interrogatory No. 9. Identify the nonprivileged documents supporting Your position about [SPECIFIED INCIDENT OR TRANSACTION].

Interrogatory No. 10. Identify the electronic systems or repositories within Your possession, custody, or control that contain information about [SPECIFIED SUBJECT].

Interrogatory No. 11. State the facts supporting Your contention that [IDENTIFIED THIRD PARTY] caused or contributed to [IDENTIFIED HARM], if You make that contention.

Interrogatory No. 12. [INSERT CASE-SPECIFIC INTERROGATORY; COUNT DISCRETE SUBPARTS].

Signature

Dated: [__/__/____]

___________________________________
[ATTORNEY NAME], Idaho State Bar No. [____]
Attorney for [PROPOUNDING PARTY]
[FIRM / ADDRESS / TELEPHONE / EMAIL]

Certificate of Service

I certify that on [__/__/____], I served these interrogatories on [COUNSEL OR UNREPRESENTED PARTY NAME] at [ADDRESS OR SERVICE CONTACT] by the method checked below:

☐ Idaho File and Serve electronic service to the designated service contact under I.R.E.F.S. 17
☐ Electronic mail with recipient's written consent under I.R.C.P. 5(b)(2)(E)
☐ First-class U.S. mail, postage prepaid
☐ Hand delivery
☐ Other authorized method: [____________]

___________________________________
[ATTORNEY NAME]