Louisiana State Court Discovery Interrogatories

[________________________________] JUDICIAL DISTRICT COURT

FOR THE PARISH OF [________________________________]

STATE OF LOUISIANA

Docket No.: [________________________________]

Division: [____]

[________________________________],
Plaintiff,

v.

[________________________________],
Defendant.

PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT

FILED: [__/__/____]

ATTORNEY INFORMATION

Propounding Attorney:

Date of Service: [__/__/____]

I. INTRODUCTORY STATEMENT

Pursuant to Louisiana Code of Civil Procedure ("La. C.C.P.") Articles 1457 through 1459 and all other applicable provisions of Louisiana law, Plaintiff [________________________________] hereby propounds the following Interrogatories upon Defendant [________________________________], to be answered separately and fully, in writing, and under oath.

Response Deadline

Under La. C.C.P. Article 1458, Defendant must serve sworn written answers and any objections within fifteen (15) days after service of these Interrogatories. However, if these Interrogatories are served together with the Petition, Defendant may respond within thirty (30) days after service of the Petition. The Court may allow a shorter or longer time upon motion for good cause shown.

Interrogatory Limit

Pursuant to La. C.C.P. Article 1457, written interrogatories served during the entire proceeding shall not exceed thirty-five (35) in number, including subparts, without leave of court. Each discrete subpart counts as a separate interrogatory toward the thirty-five-interrogatory limit. Local rules of court may impose a greater restriction on the number of interrogatories. This First Set contains [____] interrogatories (including subparts).

Additional Interrogatories

Under La. C.C.P. Article 1457(B), additional interrogatories not to exceed thirty-five may be allowed upon ex parte motion. Thereafter, additional interrogatories require a written motion, contradictory hearing, and a showing of good cause.

Continuing Obligation

These Interrogatories are continuing in nature. Defendant must seasonably supplement answers in accordance with La. C.C.P. Article 1428 whenever additional or corrective information becomes available.

II. DEFINITIONS

For purposes of these Interrogatories, the following terms shall have the meanings set forth below:

1. "You," "Your," or "Defendant" means [________________________________], including all present and former parents, subsidiaries, affiliates, divisions, officers, directors, managers, members, partners, employees, agents, servants, representatives, attorneys, insurers, and all other persons or entities acting or purporting to act on Defendant's behalf.

2. "Plaintiff" means [________________________________], including its agents, representatives, and attorneys.

3. "Document" or "Documents" has the broadest meaning allowed by La. C.C.P. Article 1461, including all forms of recorded information, electronically stored information ("ESI"), tangible things, writings, drawings, graphs, charts, photographs, sound recordings, images, and other data or data compilations stored in any medium from which information can be obtained. This includes drafts, non-identical copies, and associated metadata.

4. "Communication" means any transmission or exchange of information by any means, whether oral, written, or electronic, including but not limited to letters, memoranda, emails, text messages, instant messages, voicemails, social media messages, telephone conversations, and in-person discussions.

5. "Identify" when used with respect to:

• (a) A natural person -- state the person's full legal name, present or last-known home and business addresses, telephone number(s), email address(es), present or last-known employer and job title, and the person's relationship to any party in this action.
• (b) A business or other entity -- state its full legal name, form of organization (corporation, LLC, partnership, etc.), state of incorporation or organization, address of its principal place of business, and the name and title of the entity's representative most knowledgeable about the subject matter in question.
• (c) A document -- state its title, date, author(s), recipient(s), general subject matter, type of Document (e.g., email, contract, report), and the identity of its present custodian.

6. "Incident" means the events, acts, omissions, and circumstances giving rise to this action, as described in the Petition, occurring on or about [__/__/____] at [________________________________].

7. "Relevant Period" means the time period from [__/__/____] through the present, unless otherwise specified in an individual Interrogatory.

8. "Person" means any natural person, corporation, limited liability company, partnership, association, governmental body, or any other legal entity.

9. "Concerning" or "Relating to" means referring to, describing, evidencing, constituting, mentioning, reflecting, connected with, commenting on, regarding, or pertaining to, in whole or in part.

III. INSTRUCTIONS

1. Answer each Interrogatory separately and fully, in writing and under oath, pursuant to La. C.C.P. Article 1458. Each answer must be preceded by the full text of the Interrogatory to which it responds.

2. If any Interrogatory is objected to in whole or in part, state with specificity the grounds for each objection and respond to the Interrogatory to the extent it is not objectionable. See La. C.C.P. Article 1458.

3. If You withhold any information on the basis of attorney-client privilege, work-product doctrine, or any other privilege or protection, You must: (i) expressly identify the privilege claimed; and (ii) provide a privilege log that identifies the Document or information withheld, states the privilege asserted, and provides sufficient detail to permit evaluation of the claim, consistent with La. C.C.P. Article 1424.

4. Whenever knowledge or information contained in an answer is not within Your personal knowledge, identify the person(s) who possess such knowledge and state the source of the information provided.

5. An answer stating that You lack sufficient information or knowledge to respond must detail the efforts made to obtain the information.

6. These Interrogatories are continuing. Defendant must seasonably supplement or correct responses in accordance with La. C.C.P. Article 1428. Failure to supplement may result in exclusion of evidence or other sanctions.

7. The singular shall include the plural and vice versa; the masculine shall include the feminine and neuter and vice versa; "and" shall include "or" and vice versa, as necessary to make each Interrogatory inclusive rather than exclusive.

8. Each discrete subpart of an Interrogatory counts as a separate interrogatory toward the thirty-five-interrogatory limit imposed by La. C.C.P. Article 1457.

9. Unless otherwise specified, these Interrogatories cover the Relevant Period defined above.

IV. INTERROGATORIES

Interrogatory No. 1:
Identify every person who prepared, reviewed, or supplied information used in answering these Interrogatories, and for each such person state the specific Interrogatories for which the person supplied information.

Interrogatory No. 2:
State Your full legal name, all trade names, assumed names, or d/b/a designations used in the last ten (10) years, and the address of Your principal place of business.

Interrogatory No. 3:
Describe in detail Your involvement in the Incident, including Your conduct immediately before, during, and after the Incident.

Interrogatory No. 4:
Identify all witnesses to the Incident and for each witness provide: (a) full name and contact information; (b) a summary of the substance of each witness's expected testimony; and (c) whether You or Your representatives have obtained a statement from the witness.

Interrogatory No. 5:
Identify all Documents and ESI that relate to the Incident, including photographs, videos, surveillance footage, emails, text messages, maintenance logs, inspection reports, and internal correspondence.

Interrogatory No. 6:
State the factual basis for each affirmative defense asserted in Your Answer, including identification of all Documents, witnesses, and evidence supporting each defense.

Interrogatory No. 7:
If You contend that Plaintiff was comparatively at fault under Louisiana Civil Code Article 2323, describe each act or omission You attribute to Plaintiff and identify all evidence supporting that contention.

Interrogatory No. 8:
Identify all insurance policies (primary, excess, umbrella, and surplus lines) that may provide coverage for the claims asserted in this action. For each policy, state: (a) the name and address of the insurer; (b) the policy number; (c) the policy period; (d) per-occurrence and aggregate limits of liability; (e) applicable deductible or self-insured retention; and (f) any applicable exclusions or endorsements that may affect coverage.

Interrogatory No. 9:
Identify each expert witness You have retained or anticipate retaining for trial, and for each expert provide: (a) the expert's full name, business address, and specialty; (b) the subject matter on which the expert is expected to testify; (c) the facts, data, or opinions to which the expert is expected to testify; and (d) a summary of the grounds for each opinion.

Interrogatory No. 10:
Describe all repairs, alterations, modifications, or remedial measures made to the property, equipment, premises, or instrumentality involved in the Incident after the date of the Incident, identifying: (a) the date of each repair or modification; (b) the nature of the work performed; (c) the cost; and (d) the person(s) who performed the work.

Interrogatory No. 11:
State all damages, costs, or expenses You claim or expect to incur as a result of the Incident, specifying each category of damage and the amount claimed for each.

Interrogatory No. 12:
Identify any investigation conducted by You or on Your behalf Concerning the Incident, and state: (a) the name of the person(s) who directed the investigation; (b) the dates the investigation was conducted; (c) the identity of each person interviewed; and (d) whether any written or recorded statements were obtained.

Interrogatory No. 13:
Describe Your document retention and destruction policies in effect at the time of the Incident and any litigation hold implemented thereafter, including: (a) the date the hold was issued; (b) the person who issued the hold; (c) the scope of the hold; and (d) the steps taken to ensure compliance.

Interrogatory No. 14:
If You contend that a non-party is wholly or partially responsible for Plaintiff's alleged damages, identify each such non-party, state the basis of responsibility, and identify all supporting evidence.

Interrogatory No. 15:
Describe any disciplinary action, criminal citation, regulatory investigation, or governmental inquiry that arose out of or relates to the Incident, including the agency or body involved, the date(s), and the current status or disposition.

Interrogatory No. 16:
Identify all contracts, purchase orders, leases, maintenance agreements, or other written agreements that relate to the subject matter of this litigation, stating for each: (a) the parties; (b) the date; (c) the general subject matter; and (d) the present custodian.

Interrogatory No. 17:
State whether You have filed or intend to file any claims for indemnity or contribution arising out of the Incident under La. C.C.P. Article 1111 et seq. or any other provision of law, and for each such claim identify: (a) the party against whom the claim is or will be asserted; (b) the legal basis; and (c) the amount claimed.

Interrogatory No. 18:
Describe each Communication between You and Plaintiff (or Plaintiff's representatives) regarding the Incident, including: (a) the date; (b) all participants; (c) the medium (e.g., telephone, email, in-person); and (d) the substance of the Communication.

Interrogatory No. 19:
Identify all social media accounts (including but not limited to Facebook, Instagram, X/Twitter, LinkedIn, TikTok, and YouTube) maintained by You or Your agents that contain content that references, depicts, or relates to the Incident or the subject matter of this litigation.

Interrogatory No. 20:
Identify all prior lawsuits, administrative proceedings, or regulatory actions in which You have been a party within the past ten (10) years involving claims similar to those asserted in this action, stating for each: (a) the court or tribunal; (b) the case caption and docket number; (c) the nature of the claims; and (d) the final disposition.

V. CASE-SPECIFIC INTERROGATORIES

The following blank interrogatories are provided for case-specific questions. The total number of interrogatories including subparts from Sections IV and V combined must not exceed thirty-five (35) without leave of court. See La. C.C.P. Article 1457.

Interrogatory No. 21:
[________________________________]

Interrogatory No. 22:
[________________________________]

Interrogatory No. 23:
[________________________________]

Interrogatory No. 24:
[________________________________]

Interrogatory No. 25:
[________________________________]

VI. VERIFICATION

(To be completed by the responding party when answering)

STATE OF LOUISIANA
PARISH OF [________________________________]

BEFORE ME, the undersigned Notary Public, personally came and appeared:

[________________________________]

who, after being duly sworn, stated that:

☐ He/She is the Defendant in the above-captioned action.

☐ He/She is the [________________________________] (title/position) of Defendant [________________________________] and is authorized to make this verification on Defendant's behalf.

He/She has read the foregoing Answers to Plaintiff's First Set of Interrogatories and the matters and things stated therein are true and correct to the best of his/her knowledge, information, and belief, as required by La. C.C.P. Article 1458.

Signature: [________________________________]
Printed Name: [________________________________]
Title: [________________________________]

SWORN TO AND SUBSCRIBED before me this [____] day of [________________________________], 20[____].

Signature: [________________________________]
NOTARY PUBLIC
Notary ID / Bar Roll No.: [________________________________]
My Commission Expires: [________________________________]

(Louisiana notaries public are generally appointed for life unless otherwise specified.)

VII. CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing Plaintiff's First Set of Interrogatories to Defendant [________________________________] was served on all counsel of record on this [____] day of [________________________________], 20[____], by the method indicated below, in accordance with La. C.C.P. Article 1313 and any applicable court rules:

Method of Service:

☐ Hand delivery
☐ United States mail, postage prepaid
☐ Certified mail, return receipt requested
☐ Facsimile transmission
☐ Electronic filing and service through the Court's e-filing system
☐ Email (by agreement of counsel)
☐ Other: [________________________________]

Served Upon:

[________________________________], Esq.
[________________________________] (Firm Name)
[________________________________] (Street Address)
[________________________________] (City, State, ZIP)
[________________________________] (Telephone)
[________________________________] (Email)
Louisiana Bar Roll No.: [________________________________]

Signature: [________________________________]
[________________________________], Esq.
Counsel for Plaintiff
[________________________________] (Firm Name)
[________________________________] (Street Address)
[________________________________] (City, State, ZIP)
[________________________________] (Telephone)
[________________________________] (Email)
Louisiana Bar Roll No.: [________________________________]

VIII. PRACTICE NOTES

A. Louisiana-Specific Discovery Considerations

1. Thirty-Five Interrogatory Limit. La. C.C.P. Article 1457 limits interrogatories to 35, including subparts, during the entire proceeding. Each discrete subpart counts as a separate interrogatory. Local parish rules may impose a lower limit; always check local rules.

2. Additional Interrogatories. Under La. C.C.P. Article 1457(B), an additional 35 interrogatories may be served upon ex parte motion. Beyond that, a contradictory hearing with a showing of good cause is required.

3. Short Response Deadline. Louisiana's default response period of 15 days (La. C.C.P. Article 1458) is among the shortest in the nation. When interrogatories accompany the Petition, the response deadline extends to 30 days. Practitioners should be mindful of this short deadline when planning discovery.

4. Comparative Fault. Louisiana is a pure comparative fault jurisdiction under La. C.C. Article 2323. Interrogatories should address the responding party's contentions regarding allocation of fault among all parties and non-parties.

5. Louisiana Notarization. Louisiana has a unique notarial system. Notaries public in Louisiana are generally appointed for life (unless a limited commission is specified). The verification must be executed before a Louisiana notary public or, if executed out of state, before a notary public of that state with appropriate attestation.

6. Civil Law Jurisdiction. Louisiana is a civil law jurisdiction, and its Code of Civil Procedure differs in structure and terminology from common-law states. Practitioners from other jurisdictions should familiarize themselves with Louisiana-specific terminology (e.g., "Petition" instead of "Complaint," "Exceptions" instead of "Motions to Dismiss").

7. Motions to Compel. If Defendant fails to answer or provides inadequate answers, Plaintiff may file a motion to compel under La. C.C.P. Article 1469. The motion should demonstrate that the movant made a good-faith effort to resolve the dispute before seeking court intervention.

8. Sanctions. La. C.C.P. Article 1471 authorizes sanctions for failure to comply with discovery obligations, including orders establishing facts, precluding evidence, striking pleadings, dismissing the action, or rendering default judgment, as well as attorney's fees and costs.

9. Privilege Logs. When withholding information based on privilege, the responding party must provide a privilege log consistent with La. C.C.P. Article 1424 identifying each withheld document or communication with sufficient detail to permit assessment of the privilege claim.

B. Parish-Specific Filing Notes

10. Local Rules. Each parish court may have local rules that affect discovery practice, including rules that further restrict the number of interrogatories or impose specific formatting requirements. Check the local rules for the applicable judicial district court.

11. Electronic Filing. Many Louisiana district courts use electronic filing systems. Verify whether electronic filing is mandatory in the applicable parish and ensure compliance with local e-filing requirements.

12. Case Management Orders. Review any applicable scheduling order or case management plan for discovery deadlines that may differ from the default Code of Civil Procedure timelines.

IX. SOURCES AND REFERENCES

• Louisiana Code of Civil Procedure, Article 1421 -- Discovery Methods
• Louisiana Code of Civil Procedure, Article 1422 -- Scope of Discovery
• Louisiana Code of Civil Procedure, Article 1424 -- Protective Orders
• Louisiana Code of Civil Procedure, Article 1428 -- Supplementation of Responses
• Louisiana Code of Civil Procedure, Article 1457 -- Interrogatories to Parties; Availability
• Louisiana Code of Civil Procedure, Article 1458 -- Interrogatories to Parties; Procedures
• Louisiana Code of Civil Procedure, Article 1459 -- Interrogatories to Parties; Scope; Use at Trial
• Louisiana Code of Civil Procedure, Article 1461 -- Production of Documents
• Louisiana Code of Civil Procedure, Article 1469 -- Failure to Comply; Sanctions
• Louisiana Code of Civil Procedure, Article 1313 -- Service of Pleadings
• Louisiana Civil Code Article 2323 -- Comparative Fault
• Louisiana Legislature: https://www.legis.la.gov

This template is designed for use in Louisiana state district courts. Practitioners should verify all Code of Civil Procedure citations, confirm any applicable local parish rules and standing orders, and tailor interrogatories to the specific claims and defenses at issue. The total number of interrogatories including subparts must not exceed 35 without leave of court under La. C.C.P. Article 1457.