State Court Discovery - Interrogatories - Kentucky

I. CAPTION

COMMONWEALTH OF KENTUCKY
[CIRCUIT/DISTRICT] COURT
☐ DIVISION
[COUNTY] CIRCUIT COURT

CASE NO... [___]

[PLAINTIFF NAME],
Plaintiff,

v. PLAINTIFF’S FIRST SET OF
INTERROGATORIES TO
DEFENDANT [DEFENDANT NAME]

[DEFENDANT NAME],
Defendant.

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## II. INTRODUCTORY NOTICE

Count and deadline control. Before service, enter the governing rule or order [CITATION], cumulative interrogatory count and subpart method [DETAILS], leave, stipulation, or local-limit status [DETAILS], service date and method [DETAILS], response period [DETAILS], and calculated response date [DATE]. This form states no default number or period.

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## III. DEFINITIONS

For purposes of these Interrogatories, the following definitions apply unless expressly stated otherwise:

1. “You,” “Your,” or “Defendant” means [DEFENDANT NAME], its present and former officers, directors, employees, agents, representatives, attorneys, and all other persons acting or purporting to act on its behalf.

2. “Document(s)” and “Electronically Stored Information” (“ESI”) are used in the broadest sense and include, without limitation, all writings, drawings, graphs, charts, photographs, sound recordings, images, and other data or data compilations, however stored or maintained.

3. “Identify” (a) when referring to an individual, means to state the person’s full name, present or last-known address, telephone number, email address, and employment position during the relevant time period; (b) when referring to an entity, means to state the entity’s full name, address of principal place of business, and nature of the entity; and (c) when referring to a document, means to state its date, author(s), recipient(s), title or subject line, type (e.g., email, letter, spreadsheet), and present custodian.

4. “Communication” means any transmission of information by any means, including oral, written, or electronic statements.

5. “Incident” refers to the events alleged in the pleadings dated [DATE] giving rise to this action.

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## IV. GENERAL INSTRUCTIONS

A.  Answer each Interrogatory separately, fully, and under oath.

B.  If any Interrogatory cannot be answered in full, answer to the extent possible, stating the reason for your inability to answer the remainder and what efforts were made to obtain the information.

C.  When an Interrogatory requests identification of documents or ESI withheld on the basis of privilege, you shall:
   1. State the nature of the privilege asserted (e.g., attorney-client, work product); and
   2. Provide a privilege log that enables Plaintiff and the Court to assess the claim without revealing privileged content, consistent with Ky. R. Civ. P. 26.02.

Supplementation control. Apply only the duty supplied by the current governing rule, order, or agreement: [CITATION / TERMS / NONE IDENTIFIED]. Do not label these interrogatories “continuing” or demand supplementation beyond that authority.

E.  Unless otherwise specified, the relevant time period is [DATE RANGE].

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## V. INTERROGATORIES

1. State your full legal name, current residence address, date of birth, and Social Security number (last four digits only).

2. Identify every person who prepared, reviewed, or assisted in preparing the answers to these Interrogatories, specifying the particular Interrogatories with which each individual assisted.

3. Identify all persons whom you expect to call as witnesses at trial, summarizing the subject matter of each witness’s expected testimony.

4. Identify all documents and ESI that you may introduce as exhibits at trial and state the purpose for which each will be offered.

5. Describe in detail your version of the Incident, including the date, time, location, sequence of events, and all persons present.

6. Identify all statements—oral, written, or recorded—made by any party or witness regarding the Incident, stating for each:
   a. The date of the statement;
   b. The person making the statement;
   c. The person to whom the statement was made; and
   d. The present custodian of any recording, transcription, or summary.

7. State the name and address of every person known to you who witnessed the Incident or has knowledge of facts relevant to the claims or defenses, and provide a brief synopsis of each person’s knowledge.

8. Identify each photograph, video, or audio recording depicting any aspect of the Incident or its aftermath.

9. Describe any investigation you or anyone on your behalf conducted concerning the Incident, including the dates, scope, and conclusions of such investigation.

10. State all facts supporting each affirmative defense pleaded in your Answer and identify all documents and witnesses upon which you rely.

11. If you contend that Plaintiff was comparatively negligent or otherwise at fault, state all facts supporting such contention and identify all evidence supporting same.

12. Describe in detail any insurance agreement 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 a judgment, including:
    a. Name of insurer;
    b. Policy number;
    c. Policy limits; and
    d. Applicable endorsements.

13. Itemize and describe all damages you claim to have suffered as a result of the Incident, including the method of calculation for each category of damages.

14. Identify each expert witness you have retained or expect to retain, stating:
    a. Name and address;
    b. Field of expertise;
    c. Subject matter on which the expert is expected to testify;
    d. Summary of the expert’s opinions; and
    e. The factual basis for each opinion.

15. Identify all healthcare providers who have treated you for injuries allegedly related to the Incident, and state the dates of treatment and the diagnoses rendered.

16. State whether you were convicted of any felony or misdemeanor involving dishonesty or false statement within the past ten (10) years, and for each conviction state the court, date, charge, and sentence imposed.

17. Describe any alterations, repairs, or modifications made to the scene or instrumentalities involved in the Incident after the date of the Incident, stating the date, purpose, and persons involved in each alteration.

18. State the make, model, year, and Vehicle Identification Number (VIN) of every vehicle involved in the Incident, and identify the owner and operator of each at the time.

19. Describe any safety policies, procedures, manuals, or training relevant to the Incident that were in effect on the date of the Incident, and identify all documents reflecting same.

20. Identify each claim, lawsuit, or administrative proceeding (other than the present case) in which you have been involved within the past ten (10) years that concerns allegations similar to those in this action.

21. If you claim spoliation or loss of evidence prejudices your defense, identify the evidence allegedly lost, the circumstances under which it was lost or destroyed, and the prejudice claimed.

22. Identify all social media accounts you maintained on the date of the Incident and for the twelve (12) months thereafter, including usernames and platforms.

23. State all facts supporting your contention that any non-party is wholly or partially liable for the damages alleged, and identify all evidence supporting that contention.

24. Describe with particularity any settlement negotiations related to the Incident (excluding privileged attorney–client communications), identifying the participants, dates, and general content of each communication.

25. Identify all documents you have withheld from production on any ground, other than privilege asserted in a separate privilege log, and state the basis for withholding each such document.

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## RESPONSE VERIFICATION CONTROL

The propounding paper does not prescribe a verification method. Before answers are served, enter the current rule or order, authorized signer, oath or declaration text, and any jurat requirement: [DETAILS]. Delete unused oath, declaration, and notary options.

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## VII. CERTIFICATE OF SERVICE

I hereby certify that on this the ___ day of __________, 20___, a true and correct copy of the foregoing Plaintiff’s First Set of Interrogatories to Defendant [Defendant Name] was served upon the following by [electronic filing system / U.S. Mail / hand-delivery]:

[Opposing Counsel Name]
[Law Firm]
[Address]
[Email]

_________________________________
Counsel for Plaintiff
[Attorney Name (Bar No. ______)]
[Law Firm]
[Address]
[Phone] | [Email]

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