State Court Discovery - Interrogatories - Indiana

Indiana Litigation & Court Documents Updated October 11, 2026 Free Word and PDF

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

To [Opposing Party Name]

I. CAPTION

IN THE [CIRCUIT / SUPERIOR] COURT OF [________] COUNTY, INDIANA
Cause No. [________________]

Party	Role
[PLAINTIFF NAME],	Plaintiff
v.
[DEFENDANT NAME],	Defendant

II. INTRODUCTORY STATEMENT

Pursuant to Indiana Trial Rule 33 and any applicable local rules or case-management orders, [Plaintiff/Defendant] serves the following Interrogatories. Serve separate written answers or specific objections within [____] days after service, a period of at least thirty (30) days unless the court allows a shorter or longer time. Answers must be under oath and signed by the person answering; an attorney signs objections. General objections have no effect. See Ind. R. Trial P. 33(B)-(C).

In addition to Rule 5(B) service or a PDF copy, serve an editable word processing copy by electronic attachment or labeled disk under Rule 26(A.1)(a), or serve the verified inability statement allowed by Rule 26(A.1)(b). If using email, include an electronic memorandum with the case caption, document, and word processing version.

III. DEFINITIONS

Unless the context indicates otherwise, the following definitions apply throughout these Interrogatories:

“You,” “Your,” or “Defendant/Plaintiff” means the party to whom these Interrogatories are directed, including information available to that party through its officers or agents, subject to applicable privileges and protections.
“Document” or “Documents” includes written and electronic records relevant to the claims or defenses, including electronically stored information (“ESI”).
“Communication” means any transmission of information, whether oral, written, electronic, or otherwise.
“Person” includes any natural person, corporation, partnership, association, governmental entity, or other legal or business entity.
“Identify” means:
a. With respect to a natural person: state the full name, last known address, telephone number, employer, and title or position.
b. With respect to a document: state the title, date, author, recipient(s), general subject matter, and present custodian or location.
c. With respect to an entity: state its full legal name, address, and the identity of a contact individual familiar with the matter.

IV. INSTRUCTIONS

Supplementation: Supplement or amend answers only when required by Ind. R. Trial P. 26(E), a court order, or party agreement; a complete response is not automatically a continuing response.
Privilege Description: If you withhold otherwise discoverable information based on privilege or trial-preparation protection, state the claim expressly and describe what is withheld enough to allow evaluation of the claim without disclosing protected content. Ind. R. Trial P. 26(B)(5).
Completeness: Answer each Interrogatory fully. If you cannot answer in full, answer to the extent possible, explaining why completeness is unavailable and what efforts were made to obtain the missing information.
Objections: State any objection with specificity and answer the remainder of the Interrogatory to the extent it is not objectionable.
Time Frame: Unless otherwise stated, the relevant time period is ☐ to the present.
Scope and Number: This draft contains twenty-five interrogatories; tailor the number and scope to the case, any court order, and applicable local rules. Ind. R. Trial P. 33(D) requires reasonable particularity.