[// GUIDANCE: Replace all bracketed, ALL-CAP placeholders before serving.]

TABLE OF CONTENTS

1. Document Header & Caption
2. Preliminary Statement
3. Definitions
4. General Instructions
5. Interrogatories
6. Verification (for Responding Party)
7. Certificate of Service

1. DOCUMENT HEADER & CAPTION

IN THE DISTRICT COURT OF [_____] COUNTY, KANSAS
[CIVIL DIVISION]

[PLAINTIFF FULL LEGAL NAME], )
Plaintiff, )
)
v. ) Case No. [____]
)
[DEFENDANT FULL LEGAL NAME], )
Defendant. )

PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT

Pursuant to K.S.A. § 60-233 and the [Scheduling Order dated ___], [Plaintiff] propounds the following Interrogatories to [Defendant]. Answers shall be served within thirty (30) days after service of these Interrogatories, or forty-five (45) days from service of the summons and Petition upon a newly-served Defendant, unless the Court orders otherwise.

[// GUIDANCE: Verify local rule, case-specific scheduling orders, and any stipulations altering these default periods.]

2. DEFINITIONS

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

1. “Action” means the above-captioned lawsuit, including all claims, defenses, counterclaims, crossclaims, and third-party claims.
2. “You” or “Your” means [Defendant], its agents, representatives, employees, attorneys, investigators, insurers, predecessors, successors, affiliates, and all other persons or entities acting or purporting to act on its behalf.
3. “Document” and “Electronically Stored Information” (“ESI”) have the broadest meanings permitted by K.S.A. § 60-226, including writings, drawings, graphs, charts, photographs, sound recordings, images, data, and data compilations—regardless of medium or format.
4. “Identify” (with respect to a Person) means to provide the Person’s full name, present or last known address and telephone number, and relationship to the parties.
5. “Incident” means the events, transactions, or occurrences described in the Petition dated [____].
6. “Communication” means any transmission of information by any means, including oral, written, or electronic.
7. “Person” means any natural person, firm, corporation, partnership, association, governmental body, or other legal entity.

3. GENERAL INSTRUCTIONS

1. Answer Fully & Separately. Each Interrogatory must be answered separately and fully in writing under oath. K.S.A. § 60-233(b).
2. Duty to Supplement. You must seasonably amend or supplement Your responses in compliance with K.S.A. § 60-226(e).
3. Number Limit. By serving this set, Plaintiff does not exceed the numerical limit of [25] Interrogatories (including discrete subparts) allowed without leave of Court under K.S.A. § 60-233(a).
   [// GUIDANCE: Confirm the current statutory maximum—presently 25—and adjust if Court order or stipulation permits additional Interrogatories.]
4. Objections. State each objection with specificity. If an Interrogatory is objectionable in part, answer the unobjectionable portion.
5. Privilege Log. Information withheld on a claim of privilege must be described in a manner that enables assessment of the claim, consistent with K.S.A. § 60-226(b)(5).
6. Incorporation by Reference. Where answers refer to Documents or ESI, produce such materials concurrently or identify them with sufficient detail to permit ready location and inspection.

4. INTERROGATORIES

[// GUIDANCE: Tailor, add, or remove Interrogatories to match the pleadings and substantive claims.]

1. Identify all Persons with knowledge of any facts alleged in the Petition or Your Answer, and for each Person describe the subject matter of his or her knowledge.
2. State the factual basis for each denial contained in Your Answer.
3. State the factual basis for each affirmative defense asserted in Your Answer.
4. Describe in detail the events comprising the Incident, including dates, times, locations, participants, and sequence of events.
5. Identify and describe all Documents and ESI that support or refute any claim or defense in this Action.
6. State the nature and amount of any damages You claim to have incurred as a result of the Incident, including methodology of computation.
7. Identify all insurance agreements under which any Person carrying on an insurance business may be liable to satisfy part or all of a judgment in this Action or to indemnify or reimburse for payments made to satisfy the judgment.
8. Describe any investigations conducted regarding the Incident, including the identity of investigators, dates of investigation, and materials generated.
9. Identify each expert witness You expect to call at trial, stating the subject matter, substance of facts and opinions, and a summary of the grounds for each opinion.
10. Describe all Communications between You and any Plaintiff regarding the Incident or the claims in this Action.
11. Identify any settlement negotiations, offers, or agreements relating to the claims at issue, stating dates, participants, and terms.
12. State whether You contend any third party is partially or wholly responsible for the alleged damages, and if so, identify the third party and the conduct forming the basis of such responsibility.
13. Identify all safety policies, procedures, or guidelines in effect at the time of the Incident that are relevant to this Action.
14. Describe any remedial measures taken after the Incident and identify all Documents and Persons related thereto.
15. Identify all prior claims, lawsuits, or administrative proceedings in which You have been involved within the past ten (10) years that are factually similar to the claims asserted here.

5. VERIFICATION (TO BE COMPLETED BY RESPONDING PARTY)

STATE OF _ )
) ss:
COUNTY OF ______ )

I, ______, being first duly sworn, depose and state
that I am the [TITLE/POSITION] of [DEFENDANT]; that I have read the foregoing
Answers to Interrogatories and know the contents thereof; and that the same are
true and correct to the best of my knowledge, information, and belief.

[NAME], [TITLE/POSITION]

SUBSCRIBED AND SWORN to before me on this _ day of __, 20___.

Notary Public
My Commission Expires: ___
[// GUIDANCE: Kansas requires responses to be signed by the answering party AND counsel per K.S.A. § 60-233(b)(5).]

6. CERTIFICATE OF SERVICE

text
I hereby certify that on the ___ day of _, 20, I served the foregoing
Plaintiff’s First Set of Interrogatories to Defendant upon all counsel of record
via [state method of service authorized by K.S.A. § 60-205], addressed as
follows:

[NAME & ADDRESS OF OPPOSING COUNSEL]

[ATTORNEY NAME, KS #__]
[LAW FIRM]
[ADDRESS]
[PHONE]
[EMAIL]
ATTORNEY FOR PLAINTIFF
[// GUIDANCE: Confirm local e-filing rules; in many Kansas districts, discovery is served but not filed with the clerk unless used in a motion or at trial (K.S.A. § 60-226(d)).]

END OF DOCUMENT