Mississippi State Court Discovery Interrogatories

MISSISSIPPI STATE COURT DISCOVERY INTERROGATORIES

IN THE [________________________________] COURT OF [________________________________] COUNTY, MISSISSIPPI

PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT

ATTORNEY INFORMATION

TABLE OF CONTENTS

1. Introductory Statement and Authority
2. Definitions
3. Instructions
4. General Interrogatories (Nos. 1-20)
5. Case-Specific Interrogatories
6. Certificate of Service
7. Practice Notes
8. Sources and References

I. INTRODUCTORY STATEMENT AND AUTHORITY

Plaintiff, [________________________________] ("Plaintiff"), by and through undersigned counsel, hereby propounds the following Interrogatories upon Defendant, [________________________________] ("Defendant"), pursuant to Rule 33 of the Mississippi Rules of Civil Procedure ("MRCP").

Count and deadline control. Before service, count each distinct question in this set and any earlier sets to this party, even if labeled as a subpart [COUNT]. Rule 33(a) permits up to 30 interrogatories as of right and requires leave of court, on a showing of necessity, for more than 30 [ORDER, IF NEEDED]. Revise any selected question that asks more than one distinct question. Enter the service date and method [DETAILS], applicable response period under Rule 33(b)(3) or a court order [DETAILS], and calculated response date [DATE]. Rule 33(b)(3) generally allows 30 days after service, or 45 days for a defendant after service of the summons and complaint, subject to a shorter or longer period allowed by the court.

Supplementation control. MRCP 26(f) requires timely supplementation or correction of an interrogatory response that the responding party learns is materially incomplete or incorrect, unless the information was otherwise made known during discovery or in writing; a court order may also require supplementation. Identify any applicable order [ORDER / NONE].

II. DEFINITIONS

For purposes of these Interrogatories, the following terms shall have the meanings set forth below. Defined terms apply regardless of capitalization:

A. "Action" means the above-captioned lawsuit pending in the [________________________________] Court of [________________________________] County, Mississippi.

B. "Communication" means any oral, written, or electronic transmission of information, including but not limited to letters, memoranda, emails, text messages, instant messages, social media posts or messages, voicemails, telephone calls, facsimiles, video conferences, meetings, and face-to-face conversations.

C. "Concerning," "Relating to," or "Regarding" means directly or indirectly mentioning, referencing, describing, reflecting, evidencing, constituting, or in any way pertaining to the identified subject matter.

D. "Document" is defined to be synonymous in meaning and equal in scope to the usage of that term in MRCP 34 and includes, without limitation, all writings, drawings, graphs, charts, photographs, sound recordings, images, electronically stored information ("ESI"), and other data or data compilations in any medium from which information can be obtained.

E. "Identify" or "Identification" means:

• (i) For a natural person: state full legal name, all known aliases, present or last-known residential address, telephone number, email address, current employer, job title, and relationship to any party in this Action;
• (ii) For a business entity: state the full legal name, form of organization, state of formation, principal place of business address, and the identity of the individual(s) most knowledgeable about the subject matter;
• (iii) For a document: state the title or description, date, author(s), recipient(s), type (e.g., email, letter, report), Bates number (if applicable), and present custodian or location;
• (iv) For a communication: state the date, medium, participants, subject matter, and substance.

F. "Incident" means the events, occurrences, transactions, or omissions giving rise to this litigation as described in the Complaint filed herein.

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

H. "You," "Your," or "Defendant" means [________________________________] and persons acting for that party within the scope of their relevant duties, to the extent their information is available to the party. This definition does not require disclosure of privileged or protected information.

III. INSTRUCTIONS

1. Answering Under Oath. MRCP 33(a) requires each interrogatory to consist of a single question. Under MRCP 33(b)(1)-(2), each interrogatory must be answered separately and fully in writing under oath unless objected to; the person making the answers signs them, and the attorney making objections signs those objections. MRCP 26(g) separately requires a signature on discovery requests, responses, and objections by an attorney of record or, for an unrepresented party, the party personally.

2. Form of Answers. State each answer fully and separately, immediately following the text of the corresponding Interrogatory. Answers must be complete, responsive, and not evasive.

3. Objections. All objections must be stated with specificity, setting forth the particular grounds for each objection. If an Interrogatory is objectionable in part, Defendant must answer the non-objectionable portion and state the specific grounds for partial objection. Boilerplate or generalized objections are not permitted. See MRCP 33(b).

4. Privilege claims. If otherwise discoverable information is withheld as privileged or protected trial-preparation material, MRCP 26(b)(6) requires Defendant to make the claim expressly and describe the withheld material so Plaintiff can assess the claim without revealing the protected information.

5. Option to Produce Business Records. Where the answer to an Interrogatory may be derived or ascertained from business records and the burden of deriving the answer is substantially the same for either party, Defendant may specify the records in enough detail to locate and identify them as readily as Defendant could, and afford Plaintiff a reasonable opportunity to examine and copy them. See MRCP 33(d).

6. Rules of Construction. The singular includes the plural and vice versa. Words of one gender include all genders. The connectives "and" and "or" shall be construed either disjunctively or conjunctively as necessary to bring within the scope of the Interrogatory all responsive information. "Including" means "including but not limited to."

7. Time Period. Unless otherwise specified, each Interrogatory covers the period from [__/__/____] through the date of Defendant's response.

8. Computation of Time. All time periods shall be computed in accordance with MRCP 6(a). If service is by mail, add three (3) days to the response period under MRCP 6(e).

IV. GENERAL INTERROGATORIES

INTERROGATORY NO. 1: Identification of Responding Party

Identify Yourself as the responding party, using the applicable definition of "Identify" in Section II.

INTERROGATORY NO. 2: Persons Assisting in Preparation

Identify each Person who assisted in preparing Your answers to these Interrogatories.

INTERROGATORY NO. 3: Fact Witnesses

Identify each Person known to You to have knowledge of facts relevant to this Action.

INTERROGATORY NO. 4: Version of Events

Describe how the Incident occurred according to Your present knowledge.

INTERROGATORY NO. 5: Factual Basis of Affirmative Defenses

State the facts supporting the affirmative defenses in Your Answer.

INTERROGATORY NO. 6: Factual Basis of Denials

State the facts supporting Your denials of the material allegations in the Complaint.

INTERROGATORY NO. 7: Insurance Coverage

Identify each insurance policy or self-insurance arrangement that may cover a claim in this Action.

INTERROGATORY NO. 8: Expected Trial Expert Witnesses

Identify each expert witness whom You expect to call at trial to present opinion evidence.

INTERROGATORY NO. 9: Statements and Recordings

Identify each statement on which You rely to support a defense in this Action.

INTERROGATORY NO. 10: Investigations

Identify each Document concerning an investigation of the Incident conducted by or for You.

INTERROGATORY NO. 11: Prior Litigation

Identify each lawsuit, claim, or administrative proceeding to which You have been a party during the past ten years.

INTERROGATORY NO. 12: Communications with Plaintiff

Identify each Communication between You and Plaintiff concerning the Incident.

INTERROGATORY NO. 13: Damages Contested

State the facts supporting Your dispute of Plaintiff's claimed damages.

INTERROGATORY NO. 14: Mitigation of Damages

State the facts supporting any contention that Plaintiff failed to mitigate damages.

INTERROGATORY NO. 15: Third-Party Fault

State the facts supporting any contention that a nonparty caused or contributed to the claimed damages.

INTERROGATORY NO. 16: Remedial Measures

Describe any repair, modification, or remedial measure taken after the Incident that concerns an issue in this Action.

INTERROGATORY NO. 17: Safety Policies and Procedures

Identify each safety policy or procedure in effect at the time of the Incident that concerns an issue in this Action.

INTERROGATORY NO. 18: Surveillance and Recordings

Identify each surveillance, video, audio, or photographic recording of Plaintiff made by or for You.

INTERROGATORY NO. 19: Photographs and Demonstrative Evidence

Identify each photograph, diagram, or demonstrative exhibit You presently expect to use at trial.

INTERROGATORY NO. 20: Plaintiff's Conduct

State the facts supporting any contention that Plaintiff caused or contributed to the Incident.

V. CASE-SPECIFIC INTERROGATORIES

Use the following spaces only for additional, single-question interrogatories within the Rule 33(a) limit or an applicable order. Delete unused spaces before service.

INTERROGATORY NO. [____]:

[________________________________]

INTERROGATORY NO. [____]:

[________________________________]

INTERROGATORY NO. [____]:

[________________________________]

INTERROGATORY NO. [____]:

[________________________________]

INTERROGATORY NO. [____]:

[________________________________]

VI. CERTIFICATE OF SERVICE

I, [________________________________], one of the attorneys for Plaintiff, do hereby certify that I have this day served a true and correct copy of the foregoing Plaintiff's First Set of Interrogatories to Defendant via the method(s) indicated below:

Method of Service:

Select only a method valid under MRCP 5 and the applicable court's electronic-filing procedures. For electronic transmission outside the court system, confirm the receipt acknowledgment required by MRCP 5(b)(1).

☐ Mississippi Electronic Courts (MEC) / Electronic Filing

☐ United States First-Class Mail, postage prepaid

☐ Hand Delivery

☐ Facsimile

☐ Email

☐ Certified Mail, Return Receipt Requested

☐ Other: [________________________________]

Served Upon:

DATED: this the [____] day of [________________________________], 20[____].

Signature: [________________________________]

[________________________________], MSB No. [________________________________]
[________________________________] (Firm)
[________________________________] (Address)
[________________________________] (City, State, ZIP)
[________________________________] (Telephone)
[________________________________] (Email)
Attorney for Plaintiff

VII. PRACTICE NOTES

1. Answers and signatures. The responding person signs answers given under oath under MRCP 33(b)(1)-(2). An attorney signs objections the attorney makes under Rule 33(b)(2), and Rule 26(g) requires an attorney of record to sign discovery responses or objections for a represented party. Prepare the responding party's answer and oath separately from this propounding paper; check any applicable order for the form of oath.

2. Mississippi Electronic Courts (MEC). MRCP 5(b)(2) directs parties in a court using MEC to follow its service procedures. Confirm the assigned court's procedures and adjust the certificate of service accordingly.

3. Motion to Compel. If Defendant fails to answer or provides evasive or incomplete answers, Plaintiff may move to compel under MRCP 37(a). That motion must certify a good-faith conference or attempt to confer with the person or party failing to make discovery.

4. Sanctions. Failure to obey a discovery order may result in sanctions under MRCP 37(b), including striking pleadings, precluding evidence, or entering default judgment. Failure to serve answers or objections after proper service of interrogatories may result in sanctions under MRCP 37(d), including expenses and attorney fees subject to the rule's exceptions.

5. Privilege description. If information is withheld as privileged or protected trial-preparation material, make the claim expressly and describe the withheld material so other parties can assess it without revealing the protected information, as MRCP 26(b)(6) requires.

VIII. SOURCES AND REFERENCES

• Mississippi Rules of Civil Procedure, Rules 5, 6, 26, 33, 34, and 37
• Mississippi Rules of Civil Procedure (effective July 1, 2026): https://courts.ms.gov/research/rules/msrulesofcourt/2026-07-01%20Rules%20of%20Civil%20Procedure%20with%20Advisory%20Committee%20Notes%20(with%20Forms%206-8%20attached).pdf
• Mississippi Electronic Courts (MEC): https://courts.ms.gov/mec/
• Mississippi State Bar: https://www.msbar.org