STATE OF MICHIGAN
IN THE [COUNTY] CIRCUIT COURT
[PLAINTIFF], Plaintiff,
v.
[DEFENDANT], Defendant.

Case No.: [CASE NUMBER]
Hon.: [NAME OF JUDGE]

[PLAINTIFF]’S FIRST SET OF INTERROGATORIES TO [DEFENDANT]
Effective Date of Service: [DATE]

[// GUIDANCE: Caption formatted for Michigan Circuit Court. Replace bracketed fields.]

TABLE OF CONTENTS

1. Instructions & Definitions
2. General Objections
3. Interrogatories (1-[##])
4. Verification
5. Certificate of Service

1. INSTRUCTIONS & DEFINITIONS

A. Governing Rules
1. These interrogatories are propounded pursuant to Michigan Court Rule 2.309 (Interrogatories to Parties).
2. Pursuant to MCR 2.309(A)(2), no more than 20 interrogatories, including discrete sub-parts, may be served on any one party without stipulation or leave of court. The interrogatories below do not exceed that limit.
3. Answers and any objections must be served within 28 days after service of these interrogatories unless the Court orders otherwise. MCR 2.309(B)(4).
4. A party claiming any privilege or protection must expressly make the claim and produce a privilege log that complies with the requirements of MCR 2.302(B)(6).

B. Continuing Duty to Supplement
Each answer is to be verified and is subject to the continuing duty to supplement under MCR 2.302(E).

C. Definitions
For purposes of these interrogatories, the following definitions apply:
1. “Document” means any written, typed, printed, recorded, or graphic matter, including electronically stored information (“ESI”), as contemplated by MCR 2.302(B).
2. “Identify” (when referring to a person) means to state the person’s full name, present or last known address, telephone number, and relationship to the parties.
3. “Incident” means the transaction, occurrence, or event described in the pleadings dated [DATE OF PLEADINGS].
4. “You” or “Your” refers to [DEFENDANT], all present or former officers, directors, employees, agents, attorneys, and anyone acting on its behalf.
5. Other terms shall be construed in accordance with MCR 2.302 and applicable Michigan case law.

[// GUIDANCE: Add/modify definitions to suit the specific case.]

2. GENERAL OBJECTIONS

1. [DEFENDANT] objects to each interrogatory to the extent it seeks information protected by the attorney–client privilege, work-product doctrine, or any other applicable privilege or immunity.
2. [DEFENDANT] objects to each interrogatory to the extent it is vague, ambiguous, overly broad, unduly burdensome, or not relevant to any party’s claim or defense proportional to the needs of the case as required by MCR 2.302(B)(1).
3. The inclusion of general objections shall not be construed as an admission that responsive information exists or that such information would be admissible at trial.
4. All answers are given without waiving—and expressly reserving—the right to object on any ground at any time, or to amend or supplement the answers as discovery or investigation continues.

[// GUIDANCE: Counsel may tailor, delete, or add objections based on case specifics.]

3. INTERROGATORIES

Interrogatory No. 1
Identify all persons known to you who witnessed, were present during, or have knowledge of the Incident, including their contact information and a brief description of the knowledge each person possesses.

Interrogatory No. 2
State in detail the factual basis for each affirmative defense asserted in your [ANSWER / RESPONSIVE PLEADING] filed on [DATE].

Interrogatory No. 3
Itemize and describe all documents, including ESI, that support any defense to Plaintiff’s claims, and state the custodian, current location, and manner of storage for each such document.

Interrogatory No. 4
Identify every statement, admission, or communication (oral or written) made by Plaintiff that you contend supports any defense or damages limitation in this action. For each, state the date, substance, participants, and whether it was recorded.

Interrogatory No. 5
Set forth the full factual basis for your contention that Plaintiff was comparatively negligent, including the acts or omissions you attribute to Plaintiff, the time and place of each act or omission, and any documents or witnesses that support this contention.

Interrogatory No. 6
If you contend that any third party is wholly or partially responsible for the Incident or for Plaintiff’s alleged damages, identify each such third party and describe the nature and basis of the alleged responsibility.

Interrogatory No. 7
Describe in detail all insurance agreements or policies under which any person carrying on an insurance business may be liable to satisfy part or all of any potential judgment in this action, including identifying information for each policy and the amount of coverage.

Interrogatory No. 8
State the name, professional credentials, and expected testimony of each expert witness you anticipate calling at trial, and provide the information required by MCR 2.302(B)(4)(a)(i)-(iii).

Interrogatory No. 9
Describe any and all efforts you have made to preserve documents and ESI relevant to this litigation, including the date litigation hold notices were issued and to whom.

Interrogatory No. 10
If you contend that Plaintiff has failed to mitigate damages, state all facts on which you rely, identify all supporting documents, and identify all persons with knowledge of those facts.

[// GUIDANCE: Add additional interrogatories as needed, ensuring the total number (including sub-parts) does not exceed 20 without leave of court.]

4. VERIFICATION

I, [NAME OF RESPONDING PARTY REPRESENTATIVE], being first duly sworn, state that I am the [TITLE/POSITION] of [DEFENDANT] and that I have read the foregoing Answers to Interrogatories and know the contents thereof; that the same are true of my own knowledge, except as to those matters stated on information and belief, and as to those matters I believe them to be true.

[NAME], [CAPACITY]
[DEFENDANT]

Subscribed and sworn to before me on this ___ day of ____, 20__,

Notary Public, State of Michigan, County of _
My Commission Expires: _
Acting in the County of ____

[// GUIDANCE: Verification is mandatory under MCR 2.309(C). Modify notary block to comply with local practice.]

5. CERTIFICATE OF SERVICE

I hereby certify that on the ___ day of ____, 20__, I served the foregoing First Set of Interrogatories upon all counsel of record via [METHOD OF SERVICE – e.g., electronic filing system, email, hand-delivery, USPS], properly addressed to:

[List Names and Addresses of All Counsel of Record]

[ATTORNEY NAME] (P-_____)
Attorney for [PLAINTIFF]
[FIRM NAME]
[ADDRESS]
[PHONE] | [EMAIL]

[// GUIDANCE: For e-filing counties, follow the MiFILE or local e-service procedures. Update attorney signature block per State Bar of Michigan rules.]