Michigan State Court Discovery Interrogatories

PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT

STATE OF MICHIGAN — CIRCUIT COURT

STATE OF MICHIGAN
IN THE CIRCUIT COURT FOR THE COUNTY OF [________________________________]

PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT

Attorney Information

INTRODUCTORY STATEMENT

Plaintiff, [________________________________], by and through undersigned counsel, pursuant to Michigan Court Rule 2.309 (Interrogatories to Parties) and MCR 2.302 (General Rules Governing Discovery), propounds the following Interrogatories upon Defendant, [________________________________], to be answered separately, fully, in writing, and under oath.

Response Deadline: Pursuant to MCR 2.309(B)(4), Defendant must serve written answers and any objections within twenty-eight (28) days after service of these Interrogatories. However, a defendant may serve answers within forty-two (42) days after being served with the summons and complaint. The Court may allow a longer or shorter time.

Interrogatory Limit — DO NOT SERVE THIS ENTIRE BANK. Under MCR 2.309(A)(2), each separately represented party may serve no more than twenty (20) interrogatories on each party, and each discrete subpart counts separately. The modules below are an optional drafting bank. Select, tailor, count, renumber, and serve only a compliant set. A written and filed stipulation or court order may change the limit under MCR 2.302(F)(2).

Duty to Supplement: Pursuant to MCR 2.302(E), Defendant must supplement or correct a response in a timely manner if Defendant learns that it is materially incomplete or incorrect and the additional or corrective information has not otherwise been made known during discovery or in writing, or as ordered by the Court.

DEFINITIONS

For purposes of these Interrogatories, the following definitions shall apply:

1. "Action" means the above-captioned lawsuit, including all claims, counterclaims, cross-claims, and third-party claims asserted in the pleadings.

2. "Communication" means any transmission or exchange of information, whether oral, written, or electronic, including but not limited to conversations, telephone calls, emails, text messages, letters, memoranda, facsimiles, social media messages, video conferences, and any other form of information exchange.

3. "Document" means any written, printed, typed, recorded, or graphic matter of any kind, however produced or reproduced, including electronically stored information ("ESI") within MCR 2.310(A). This includes but is not limited to contracts, agreements, correspondence, memoranda, reports, studies, notes, recordings, photographs, videos, databases, spreadsheets, metadata, and any other tangible or electronic material.

4. "Describe" means to provide a detailed narrative account including all relevant facts, circumstances, dates, times, locations, and persons involved.

5. "Identify" (when referring to a natural person) means to state the person's full legal name, present or last-known residential address, present or last-known telephone number, present or last-known email address, present or last-known employer and job title, and relationship to any party in this Action.

6. "Identify" (when referring to an entity) means to state the entity's full legal name, type of entity (corporation, LLC, partnership, etc.), state of formation or incorporation, principal place of business address, and the name and contact information of its designated representative or registered agent.

7. "Incident" means the transaction, occurrence, event, or series of events giving rise to the claims and defenses in this Action, as described in the pleadings.

8. "Occurrence" has the same meaning as "Incident" and the terms are used interchangeably.

9. "You," "Your," or "Defendant" means [________________________________]. It includes information available to Defendant or obtainable from Defendant's employees, agents, representatives, sureties, or indemnitors as provided by MCR 2.309(B)(1), but does not independently impose a duty on a nonparty.

10. "Person" means any natural individual, corporation, limited liability company, partnership, association, joint venture, trust, estate, governmental entity, or any other legal or commercial entity.

11. "Relate," "Relating to," or "Concerning" means referring to, describing, evidencing, constituting, mentioning, summarizing, or reflecting the subject matter referenced, within the relevance and proportionality limits of MCR 2.302(B)(1).

INSTRUCTIONS

1. Separate Answers Required. Each Interrogatory must be answered separately and fully. Restate each Interrogatory in full immediately before the corresponding answer. Pursuant to MCR 2.309(B), each answer must include such information as is available to the party served, including information obtainable from employees, agents, representatives, sureties, and indemnitors.

2. Oath Requirement. All answers must be made under oath and signed by the party answering, not merely by counsel. MCR 2.309(B)(1) requires that each interrogatory be answered separately and fully in writing under oath.

3. Privilege or Protection Objections. If Defendant objects based on attorney-client privilege, trial-preparation protection, or another privilege or immunity, Defendant must state the reasons for the objection under MCR 2.309(B)(1). Trial-preparation and expert materials are governed by MCR 2.302(B)(3)-(4). Defendant must also comply with any scheduling order, local rule, or party agreement requiring a privilege log.

4. Supplementation Duty. Supplement or correct responses when and as required by MCR 2.302(E).

5. Objections. If Defendant objects to any Interrogatory, state the reasons for the objection in lieu of an answer as required by MCR 2.309(B)(1). Repeat each interrogatory or subquestion immediately before the corresponding answer or objection under MCR 2.309(B)(2).

6. Business Records Option. Pursuant to MCR 2.309(E), if an answer may be derived from qualifying business records and the burden of deriving it is substantially the same for both sides, Defendant may specify the records in sufficient detail and afford Plaintiff a reasonable opportunity to examine, audit, or inspect them and make copies, compilations, abstracts, or summaries.

GENERAL INTERROGATORIES

INTERROGATORY NO. 1: Party Identification

State Your full legal name, all former names or aliases, current address for service or contact, telephone number, and email address. Do not include protected personal identifying information prohibited from public filings by MCR 1.109(D)(9).

If Defendant is an entity, state the full legal name, type of entity, state of formation, date of formation, principal place of business address, all registered agent information, and the names and titles of all current officers, directors, members, or managing partners.

INTERROGATORY NO. 2: Factual Basis for Defenses

State in detail the complete factual basis for each affirmative defense, defense, or avoidance asserted in Your Answer or any amended pleading, including:

• (a) All facts supporting each defense;
• (b) The identity of each person with knowledge of facts supporting each defense;
• (c) The identity of each Document supporting each defense.

INTERROGATORY NO. 3: Witnesses

Identify every person known to You who witnessed, was present during, or has knowledge of any facts relating to the Incident or to any claim or defense in this Action. For each such person, state:

• (a) The person's full name and contact information;
• (b) A summary of the facts known to that person;
• (c) Whether a written or recorded statement has been obtained from that person, and if so, the date and custodian of the statement.

INTERROGATORY NO. 4: Documents

Identify each Document or category of Documents in Your possession, custody, or control that relates to any claim or defense in this Action, including:

• (a) A description of the Document or category;
• (b) The date or date range of the Document;
• (c) The author or creator;
• (d) The current custodian and location;
• (e) Whether the Document is in electronic or physical form.

INTERROGATORY NO. 5: Expert Witnesses

Identify each expert witness You expect to call at trial in this Action, and for each such expert provide:

• (a) The expert's full name, business address, and professional credentials;
• (b) The subject matter on which the expert is expected to testify;
• (c) The substance of the facts and opinions to which the expert is expected to testify;
• (d) A summary of the grounds for each opinion.

INTERROGATORY NO. 6: Damages

Itemize and describe all damages, losses, or injuries You contend Plaintiff has or has not suffered as a result of the Incident, including for each category of damage:

• (a) The nature of the damage;
• (b) The amount claimed or denied;
• (c) The method of calculation;
• (d) All Documents supporting or contradicting the claimed amount;
• (e) The identity of each person with knowledge of the damages calculation.

INTERROGATORY NO. 7: Insurance

Identify every insurance agreement or policy under which any person carrying on an insurance business may be liable to satisfy part or all of any potential judgment in this Action, or to indemnify or reimburse for payments made to satisfy any judgment. For each policy, state:

• (a) The name and address of the insurer;
• (b) The policy number;
• (c) The policy period;
• (d) The type and amount of coverage, including per-occurrence and aggregate limits;
• (e) Whether the insurer has accepted or denied coverage, or reserved rights;
• (f) Any applicable deductible or self-insured retention.

INTERROGATORY NO. 8: Prior Claims and Lawsuits

Identify every claim, lawsuit, administrative proceeding, or arbitration in the past ten (10) years in which You were a party and that involved allegations similar or related to those in this Action. For each, state:

• (a) The caption, case number, and court or tribunal;
• (b) The nature of the allegations;
• (c) The disposition or current status;
• (d) The amount of any judgment, settlement, or award.

INTERROGATORY NO. 9: Communications Regarding the Incident

Identify and describe all Communications between You and any other person concerning the Incident, including:

• (a) The date of the Communication;
• (b) The identity of all participants;
• (c) The method of Communication (oral, written, electronic);
• (d) The substance of the Communication;
• (e) Whether the Communication was recorded or memorialized, and if so, the custodian of the recording or document.

INTERROGATORY NO. 10: Medical Treatment (If Applicable)

If this Action involves claims for personal injury, identify every healthcare provider who has examined, treated, or consulted with Plaintiff regarding injuries allegedly arising from the Incident, including:

• (a) The provider's full name, specialty, and address;
• (b) The dates of treatment or consultation;
• (c) The nature of the treatment provided;
• (d) The diagnosis rendered;
• (e) The total charges billed and amounts paid.

INTERROGATORY NO. 11: Employment and Income (If Applicable)

If this Action involves claims for lost wages or loss of earning capacity, state:

• (a) Plaintiff's employers for the five (5) years preceding the Incident;
• (b) Plaintiff's job title, duties, and rate of compensation for each employer;
• (c) The dates of any missed work allegedly attributable to the Incident;
• (d) The total amount of wages or income allegedly lost;
• (e) Whether Plaintiff received disability, workers' compensation, or similar benefits during any period of claimed lost wages.

INTERROGATORY NO. 12: Comparative Fault

If You contend that Plaintiff was comparatively negligent or otherwise at fault for the Incident or for Plaintiff's injuries or damages, state:

• (a) Each act or omission You attribute to Plaintiff;
• (b) The time and place of each such act or omission;
• (c) The identity of each person with knowledge of Plaintiff's alleged fault;
• (d) All Documents supporting Your contention.

INTERROGATORY NO. 13: Third-Party Liability

If You contend that any third party is wholly or partially responsible for the Incident or for Plaintiff's claimed damages, identify each such third party and state:

• (a) The nature and basis of the alleged responsibility;
• (b) The facts supporting the contention;
• (c) The identity of each witness with knowledge of the third party's alleged responsibility;
• (d) All Documents supporting the contention.

INTERROGATORY NO. 14: Preservation Efforts

Subject to any applicable privilege or trial-preparation protection, describe the non-protected facts concerning efforts to identify, locate, and preserve Documents and electronically stored information relevant to this litigation, including:

• (a) The date any litigation hold notice was issued;
• (b) The persons to whom the litigation hold was directed;
• (c) The substance of the litigation hold instructions;
• (d) Any Documents or ESI that were lost, destroyed, or rendered inaccessible after the duty to preserve arose, and the circumstances of such loss or destruction.

INTERROGATORY NO. 15: Investigations

Subject to MCR 2.302(B)(3) and any applicable privilege, identify non-protected facts concerning investigations conducted by You or on Your behalf relating to the Incident or to any claim or defense in this Action, including:

• (a) The identity of each investigator;
• (b) The dates of the investigation;
• (c) The scope and purpose of the investigation;
• (d) A summary of the findings;
• (e) All reports, memoranda, or other Documents generated as a result of the investigation.

INTERROGATORY NO. 16: Statements Obtained

Subject to MCR 2.302(B)(3) and any applicable privilege, identify statements, whether written, recorded, or summarized, that You or anyone acting on Your behalf has obtained from any person concerning the Incident, including:

• (a) The name of the person providing the statement;
• (b) The date the statement was obtained;
• (c) The identity of the person who obtained the statement;
• (d) The form of the statement (written, audio recording, video, etc.);
• (e) The current custodian and location of the statement.

CASE-SPECIFIC INTERROGATORIES

INTERROGATORY NO. 17:
[________________________________]
[________________________________]
[________________________________]

INTERROGATORY NO. 18:
[________________________________]
[________________________________]
[________________________________]

INTERROGATORY NO. 19:
[________________________________]
[________________________________]
[________________________________]

INTERROGATORY NO. 20:
[________________________________]
[________________________________]
[________________________________]

Mandatory count check: This is an optional bank, not a ready-to-serve 20-question set. Under MCR 2.309(A)(2), count every discrete subpart, select only a compliant set, and renumber it before service. A written and filed stipulation or court order may change the limit under MCR 2.302(F)(2).

VERIFICATION

STATE OF MICHIGAN
COUNTY OF [________________________________]

I, [________________________________], being first duly sworn, depose and state that I am the ☐ Defendant individually / ☐ [________________________________] (title/position) of [________________________________] (Defendant entity); that I have read the foregoing Answers to Plaintiff's First Set of Interrogatories; that I know the contents thereof; and that the answers are true and complete to the best of my knowledge, information, and belief, except as to those matters stated on information and belief, and as to those matters, I believe them to be true.

Signature: [________________________________]

Printed Name: [________________________________]

Title/Capacity: [________________________________]

Date: [__/__/____]

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

Signature: [________________________________]

Notary Public, State of Michigan, County of [________________________________]

My Commission Expires: [__/__/____]

Acting in the County of [________________________________]

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 and any unrepresented parties by the method indicated below:

☐ Electronic filing and service as authorized by MCR 1.109(G)(6)(a) and the court's approved system
☐ Email or other electronic service as authorized by MCR 2.107(C)(4) or (G), including any required stipulation or agreement
☐ First-class U.S. Mail, postage prepaid
☐ Hand delivery
☐ Other: [________________________________]

Served upon:

I declare under the penalties of perjury that this proof of service has been examined by me and that its contents are true to the best of my information, knowledge, and belief.

Signature: [________________________________]

Date: [__/__/____]

[________________________________], P-[____]
Attorney for Plaintiff
[________________________________] (Firm Name)
[________________________________] (Address)
[________________________________] (Phone) | [________________________________] (Email)

PRACTICE NOTES

Michigan-Specific Discovery Rules

1. Interrogatory Limit. MCR 2.309(A)(2) limits each separately represented party to 20 interrogatories on each party and counts every discrete subpart separately. A written and filed stipulation or court order may change the limit under MCR 2.302(F)(2).

2. Response Deadline. Answers and objections generally must be served within 28 days after service. A defendant may serve answers within 42 days after being served with the summons and complaint. The court may allow a longer or shorter time. MCR 2.309(B)(4).

3. Initial Disclosures and Discovery Timing. Where initial disclosures are required, a party may seek discovery only after serving its own disclosures. MCR 2.301(A)(1). MCR 2.302(A)(4) exempts listed proceedings, including district-court actions, unless otherwise stipulated or ordered. Disclosure deadlines are governed by MCR 2.302(A)(5), not a general 14-day-after-conference rule.

4. Objection Procedures. If the answering party objects, MCR 2.309(B)(1) requires the reasons for the objection to be stated in lieu of an answer. MCR 2.309(B)(2) requires each interrogatory or subquestion to be repeated immediately before its answer.

5. Motion to Compel. Under MCR 2.309(C) and 2.313(A), the propounding party may move regarding an objection or other failure to answer. The motion must state that the movant conferred or attempted in good faith to confer to secure the disclosure without court action; a motion based on failure to serve answers must include proof of service of the interrogatories.

6. Sanctions. MCR 2.313(B) authorizes sanctions for failure to comply with a court order compelling discovery, including:

• ☐ Designating facts as established for purposes of the action
• ☐ Prohibiting the disobedient party from supporting or opposing designated claims or defenses
• ☐ Striking pleadings or parts thereof
• ☐ Staying further proceedings until the order is obeyed
• ☐ Dismissing the action or entering a default judgment
• ☐ Holding the disobedient party in contempt of court

7. Proportionality. MCR 2.302(B)(1) requires that discovery be proportional to the needs of the case, considering the importance of the issues at stake, the amount in controversy, the parties' relative access to relevant information, the parties' resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit.

8. Filing and Service. Under MCR 2.302(H), discovery materials generally may not be filed unless a rule requires filing or the court orders it. Materials used with a motion must be attached to the motion, response, or an accompanying affidavit; materials used at trial are submitted to the judge and made an exhibit rather than filed. Serve copies on all parties unless the court orders otherwise under MCR 2.107(F), and use a service method authorized by MCR 2.107 and MCR 1.109(G), as applicable.

9. Protected Identifiers. MCR 1.109(D)(9) generally prohibits dates of birth, Social Security or national identification numbers, driver's-license or state-identification numbers, passport numbers, and financial-account numbers from public documents or attachments. Redact and use the SCAO-approved personal-identifying-information process when a protected identifier must be filed.

SOURCES AND REFERENCES

• Michigan Court Rules, current official PDF (updated July 31, 2026; Chapter 1 updated January 1, 2026; Chapter 2 updated May 1, 2026), including MCR 1.109, 2.107, 2.302, 2.309, 2.310, and 2.313: https://www.courts.michigan.gov/48ec32/siteassets/rules-instructions-administrative-orders/michigan-court-rules/michigan-court-rules.pdf
• MCR 2.301 — Availability and Timing of Discovery.
• MCR 2.309 — Interrogatories to Parties.
• MCR 2.302 — General Rules Governing Discovery
• MCR 2.313 — Failure to Provide Discovery; Sanctions