STATE OF MINNESOTA

DISTRICT COURT ___ JUDICIAL DISTRICT

___ COUNTY

[PLAINTIFF NAME(S)],
  Plaintiff(s),

v.

[DEFENDANT NAME(S)],
  Defendant(s).

Court File No.: [_____]

PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT

(Pursuant to Minn. R. Civ. P. 26 & 33)

Effective Date: [DATE OF SERVICE]
Jurisdiction: State of Minnesota – State District Court

[// GUIDANCE: Insert case caption information exactly as it appears on the pleadings. Verify the judicial district and county before filing/serving.]

TABLE OF CONTENTS

I. Document Header
II. Definitions
III. Instructions & General Objections
IV. Interrogatories
V. Verification & Signature Block
VI. Certificate of Service

I. DOCUMENT HEADER

1. Purpose. These Interrogatories are propounded under Minn. R. Civ. P. 26 and 33 for the purpose of discovery in the above-captioned matter.
2. Discovery Limits. This set contains [#] interrogatories, inclusive of sub-parts, and therefore does not exceed the fifty-interrogatory limit established by Minn. R. Civ. P. 33.01.
3. Response Deadlines. Answers must be served within thirty (30) days after service of these Interrogatories, except that a defendant served with the Summons and Complaint has forty-five (45) days to serve answers. Minn. R. Civ. P. 33.01.
4. Continuing Duty. Pursuant to Minn. R. Civ. P. 26.05, answers must be seasonably supplemented or corrected.

II. DEFINITIONS

For purposes of these Interrogatories, the following terms shall have the meanings set forth below (words defined in the singular include the plural and vice-versa):

1. “Action” means the above-captioned lawsuit.
2. “Communication” means any oral or written transmission of information, including e-mails, text messages, social-media messages, letters, facsimiles, and meetings.
3. “Document” has the broadest meaning permissible under Minn. R. Civ. P. 34 and includes electronically stored information (“ESI”).
4. “Identify” (with respect to a person) means to state the person’s full name, present or last-known address and telephone number, and relationship to any party.
5. “Incident” means the events described in the Complaint that give rise to the claims and defenses in this Action.
6. “You” or “Your” means the party to whom these Interrogatories are directed, including all agents, representatives, employees, and attorneys.

III. INSTRUCTIONS & GENERAL OBJECTIONS

1. Form of Response. Each Interrogatory must be answered separately and fully, in writing, under oath, and signed by the party or, if the party is a corporation or other legal entity, by an authorized officer or agent.
2. Manner of Production. When the answer is not solely within Your personal knowledge, state the name of any person possessing such knowledge and the source of the information.
3. Privilege Log. If information is withheld under any privilege, You must:
   a. State expressly that the information is withheld; and
   b. Provide a privilege log compliant with Minn. R. Civ. P. 26.02(d) that identifies the nature of the documents, communications, or tangible things withheld.
4. Objections. State any objection with specificity. General objections not tied to a particular Interrogatory are disfavored.
5. Continuing Interrogatories. These Interrogatories are deemed continuing; promptly serve supplemental answers if additional responsive information becomes known.
6. Interpretation. The rules of construction set forth in Minn. R. Civ. P. 26-37 and the Minnesota General Rules of Practice apply.
7. Time Period. Unless otherwise stated, these Interrogatories seek information from the earliest relevant date through the present.

[// GUIDANCE: Modify or narrow instructions to align with client strategy while maintaining compliance with Minn. R. Civ. P.]

IV. INTERROGATORIES

(Customize, add, remove, or re-order to fit the specific case. Replace bracketed text with case-specific details.)

1. Identify Parties and Representatives. Identify all individuals who participated in answering these Interrogatories and state their role(s) in the underlying Incident and/or this Action.
2. Incident Description. Describe in complete detail Your version of how the Incident occurred, including the date, time, location, sequence of events, and all participants.
3. Witnesses. Identify every person known to You who witnessed or has knowledge of any facts relating to the claims or defenses in this Action. For each such person, summarize the facts to which the person is expected to testify.
4. Communications About the Incident. Identify and describe all Communications You had with any person regarding the Incident, including the date, participants, and substance of each Communication.
5. Documents and ESI. Identify each category of Document or ESI within Your possession, custody, or control that relates to the Incident, including the location and custodian of each category.
6. Injuries and Damages. Itemize and describe all injuries, damages, or losses You claim to have suffered as a result of the Incident, including amounts, calculations, and supporting Documents.
7. Insurance. Identify every 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 any judgment.
8. Experts. Identify every expert You expect to call at trial, including the subject matter and substance of the expert’s anticipated testimony, the expert’s qualifications, publications, and fee schedule.
9. Prior Claims or Lawsuits. Identify any prior claims, lawsuits, or administrative proceedings involving allegations similar to those in this Action that You have been a party to within the past ten (10) years, including docket numbers and disposition.
10. Corrective Actions. Describe any remedial or corrective actions taken by You or on Your behalf as a result of the Incident.
11. Admissions. State whether You admit or deny each material allegation in the Complaint not previously addressed in Your pleadings, and explain the basis for each denial.
12. Contentions. Identify and describe every legal or factual contention upon which You rely to oppose the relief sought by Plaintiff.

[// GUIDANCE: Total interrogatories, including numbered sub-parts, must not exceed 50 absent stipulation or court order. Tailor the substance to the specific pleadings and defenses.]

V. VERIFICATION & SIGNATURE BLOCK

I declare under penalty of perjury that the foregoing answers are true and correct to the best of my knowledge, information, and belief.

Date: ___

[NAME OF PARTY/AUTHORIZED REPRESENTATIVE]
Title (if applicable): ___

Subscribed and sworn to before me on this _ day of _, 20___.

Notary Public

[Notary Stamp/Seal]

VI. CERTIFICATE OF SERVICE

I certify that on the ___ day of _, 20, I caused the foregoing Plaintiff’s First Set of Interrogatories to Defendant to be served on the following counsel of record by [U.S. Mail / Hand Delivery / E-Service / Other Approved Method]:

• [Name, Firm, Address, E-mail]

[ATTORNEY NAME], (#__)
Attorney for Plaintiff
[FIRM NAME]
[ADDRESS]
[PHONE] | [EMAIL]

[// GUIDANCE: Confirm service method complies with Minn. R. Civ. P. 5 and with any e-filing requirements of the district.]

PRACTICAL NOTES & RISK-MITIGATION CHECKLIST

• Double-check the total number of interrogatories (including discrete subparts) to avoid exceeding the fifty-question cap.
• Ensure all defined terms are used consistently; add definitions for specialized terms unique to the case.
• Where privilege is asserted, create a robust privilege log that satisfies Minn. R. Civ. P. 26.02(d) to avoid motion practice.
• Consider whether any protective order is needed for confidential or proprietary information before serving discovery.
• Verify that all answers, when received, are signed under oath—failure to verify renders answers incomplete and potentially inadmissible.
• Maintain a discovery calendar noting the 30-day (or 45-day) response deadline and follow up promptly on any deficiencies.

[// GUIDANCE: This template is court-ready for Minnesota state district court practice. Customize interrogatory content to align with the specific causes of action and defenses at issue. Always review local rules and judge-specific standing orders for additional requirements.]