State Court Discovery - Interrogatories - Kansas

KANSAS STATE COURT DISCOVERY INTERROGATORIES

TABLE OF CONTENTS

1. Document Header & Caption
2. Definitions
3. General Instructions
4. Interrogatories
5. Response Requirements
6. Certificate of Service

1. DOCUMENT HEADER & CAPTION

IN THE DISTRICT COURT OF [____] COUNTY, KANSAS

[CIVIL DIVISION]

PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT

Response deadline. Serve answers and any objections within 30 days after service of these interrogatories. A defendant may serve answers or objections within 45 days after being served with process. The parties may stipulate to a different period under K.S.A. 60-229, or the court may order one. Court approval is required if a stipulation extending discovery time would interfere with the time set for completing discovery, a motion hearing, or trial. K.S.A. 60-233(b)(2); 60-229(b).

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]. Respond using information available to that party under K.S.A. 60-233(b)(1).
3. “Document” and “Electronically Stored Information” (“ESI”) include writings, drawings, graphs, charts, photographs, sound recordings, images, data, and data compilations, subject to K.S.A. 60-226(b)'s scope and privilege protections.
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. Supplementation. Supplement or correct a response in a timely manner if it is materially incomplete or incorrect and the new information has not otherwise been made known to the other parties during discovery or in writing, or as the court orders. K.S.A. 60-226(e)(1).

3. Number Review. K.S.A. § 60-233 does not state a statewide numerical cap on interrogatories. Confirm the scheduling order, standing order, and applicable local rules before service, and revise this set if the Court has imposed a limit.

4. Objections. State each objection with specificity. If an Interrogatory is objectionable in part, answer the unobjectionable portion.

5. Privilege Description. Information withheld on a claim of privilege or trial-preparation protection must be described in a manner that enables assessment of the claim, consistent with K.S.A. § 60-226(b)(7)(A).
6. Business Records Option. If the answer can be determined from Your business records and the burden of deriving it is substantially the same for each party, You may specify the records in enough detail for ready identification and give a reasonable opportunity to examine and copy them. K.S.A. 60-233(d).

4. INTERROGATORIES

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. RESPONSE REQUIREMENTS

The responding party must serve separately stated written answers under oath for matters not objected to. The person who makes the answers must sign them, and an attorney who objects must sign the objections. K.S.A. 60-233(b)(3)–(5).

6. CERTIFICATE OF SERVICE

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]

Signature: [________________________________]

[ATTORNEY NAME, KS #________]

[LAW FIRM]

[ADDRESS]

[PHONE]

[EMAIL]

Attorney for Plaintiff

END OF DOCUMENT

Sources and References

• K.S.A. § 60-233 — Kansas Office of Revisor of Statutes — https://ksrevisor.gov/statutes/chapters/ch60/060_002_0033.html
• K.S.A. § 60-226(b), (e) — discovery scope, privilege, and supplementation — https://ksrevisor.gov/statutes/chapters/ch60/060_002_0026.html
• K.S.A. § 60-205(b), (d) — service and filing — https://ksrevisor.gov/statutes/chapters/ch60/060_002_0005.html
• K.S.A. § 60-229 — discovery stipulations — https://ksrevisor.gov/statutes/chapters/ch60/060_002_0029.html