IN THE _ COURT OF
_ COUNTY, MISSISSIPPI

[PLAINTIFF NAME], )
Plaintiff, )
)
v. ) Cause No. [_]
)
[DEFENDANT NAME], )
Defendant. )

PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT

[// GUIDANCE: Replace bracketed items with case-specific information. Adapt, add, or delete interrogatories to fit the claims and defenses at issue. This template assumes service upon the Defendant; switch roles if serving the Plaintiff.]

I. PRELIMINARY STATEMENT
These Interrogatories are propounded pursuant to Rule 33 of the Mississippi Rules of Civil Procedure (“MRCP”) and all other applicable provisions of Mississippi law. Each Interrogatory must be answered separately, fully, and in writing, under oath, within the time prescribed by MRCP 33(b)—i.e., within thirty (30) days of service, except that a Defendant served with these Interrogatories together with process shall serve answers within forty-five (45) days after service of the summons and complaint.

II. DEFINITIONS
For purposes of these Interrogatories, the following definitions apply (words in bold have the same meaning wherever else they appear):

1. “You,” “Your,” or “Defendant” means [DEFENDANT NAME], together with all present and former agents, employees, representatives, insurers, attorneys, experts, and any other Person acting or purporting to act on Defendant’s behalf.
2. “Person” means any natural person, corporation, partnership, association, joint venture, governmental body, or any other legal or business entity.
3. “Document” and “Documents” are defined to be synonymous in meaning and equal in scope to the usage of those terms in MRCP 34 and include, without limitation, all writings, electronically stored information (“ESI”), drawings, graphs, charts, photographs, recordings, and any other data compilations, whether in hard-copy or electronic form.
4. “Communication” means any transmission of information, thoughts, or ideas by any means, including, but not limited to, oral conversations, meetings, letters, memoranda, facsimiles, electronic mail, text messages, social-media postings, or other ESI.
5. “Incident” refers to the events giving rise to this litigation, as described in the Complaint filed herein.
6. “Identify” (or “Identification”) when used:
   a. With respect to a natural person: state full name, present (or last-known) address, telephone number, present employer and position, and relationship to any party in this action.
   b. With respect to a business entity: state full name, form of organization, address of principal place of business, and the identity of the natural person(s) answering on its behalf.
   c. With respect to a document: provide the title, date, author(s), recipient(s), type (e.g., letter, email), bates numbers (if applicable), present location, and custodian.
   d. With respect to a communication: state date, medium, participants, subject matter, and substance.
7. The singular includes the plural and vice-versa; the masculine, feminine, and neuter include each other.

III. GENERAL INSTRUCTIONS
A. Answer each Interrogatory separately, fully, and under oath.
B. If any Interrogatory is objected to, state with specificity each ground for objection in the answer and respond to the remainder of the Interrogatory to the extent it is not objectionable.
C. If You withhold any information or document on the basis of privilege, work-product immunity, or other protection, comply with MRCP 26(b)(6) by producing a privilege log that: (i) describes the nature of the withheld material in sufficient detail to allow assessment of the claim; and (ii) states the specific privilege or protection asserted.
D. These Interrogatories are subject to the duty to supplement under MRCP 26(f).
E. Pursuant to MRCP 33(a), the total number of Interrogatories propounded herein, including discrete subparts, does not exceed thirty (30).

IV. INTERROGATORIES
[// GUIDANCE: Delete, modify, or rearrange Interrogatories to tailor them to your case. Ensure total discrete subparts ≤ 30 absent court leave or stipulation.]

1. State Your full legal name, any other names or aliases used during the past ten (10) years, present residence address, business address, and all e-mail addresses used during the last five (5) years.

2. Identify every Person who assisted, in whole or part, in preparing the answers to these Interrogatories and specify the subject matter of each Person’s assistance.

3. For each statement (oral, written, or recorded) that You contend supports any defense asserted in this action, identify:
   a. the Person who made the statement;
   b. the date, time, and place it was made;
   c. to whom it was made;
   d. the substance of the statement; and
   e. the present custodian of any document or recording reflecting the statement.

4. Describe in detail Your version of how the Incident occurred, including the time, date, location, sequence of events, and Persons present.

5. Identify all Documents that relate to any investigation You (or anyone acting on Your behalf) conducted concerning the Incident, and state the name of the investigator.

6. Identify all insurance policies, excess policies, or self-insured retention arrangements that may provide coverage for the claims asserted, stating for each:
   a. the insurer’s name and address;
   b. policy number;
   c. limits of liability; and
   d. any reservation-of-rights positions taken.

7. State the name, address, and specialty of each expert You have retained or specifically consulted in anticipation of litigation or for trial, and, for each testifying expert, provide the information required by MRCP 26(b)(4)(A)(i).

8. Identify every lawsuit, claim, or administrative proceeding (other than the present action) to which You have been a party within the last ten (10) years, and for each, describe the nature of the action, court or agency, docket number, and final disposition.

9. State the factual basis for each affirmative defense pled in Your Answer, identifying all Documents and witnesses that support each stated fact.

10. Describe any repairs, modifications, or remedial measures taken after the Incident and identify the Person(s) who performed such work.

11. List all Persons known or believed by You to have knowledge of any facts relevant to this action and describe the subject matter of their knowledge.

12. Identify all communications (including e-mails, text messages, or social-media posts) exchanged between You and Plaintiff relating to the Incident.

13. If You contend that Plaintiff failed to mitigate damages, state all facts supporting that contention, identify all supporting Documents, and identify the Persons with knowledge of those facts.

14. Describe any surveillance, video, audio, or photographic recordings of Plaintiff made by or on behalf of You, including date(s), location(s), surveillance company, and present custodian.

15. Identify each prior claim for personal injury or property damage made by You during the past ten (10) years, including court or agency, style, docket number, nature of injury, and outcome.

16. State whether You consumed any alcohol, medication, or other substance within 24 hours preceding the Incident; if so, identify the substance(s), amount(s), time(s) consumed, and any related medical or prescription records.

17. Provide a detailed description of any safety policies, procedures, manuals, or training materials in effect at the time of the Incident that are relevant to this action, and identify each Document embodying such policies.

18. Identify all photographs, diagrams, or other demonstrative evidence You intend to use at trial.

19. State all facts upon which You rely to contest Plaintiff’s claimed damages, including the amount of damages You admit are owed (if any).

20. If You deny liability in whole or part, state the precise legal and factual bases for such denial.

[// GUIDANCE: Insert additional Interrogatories 21–30 as required, ensuring total subparts do not exceed 30.]

V. RESERVATION OF RIGHTS
Plaintiff reserves the right to serve additional discovery as permitted under the Mississippi Rules of Civil Procedure and any scheduling order entered by the Court.

VI. CERTIFICATE OF SERVICE
I, [ATTORNEY NAME], 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

☐ United States Mail ☐ Hand Delivery ☐ Facsimile ☐ E-Mail ☐ MEC/ECF

to:

[DEFENSE COUNSEL NAME]
[LAW FIRM]
[ADDRESS]
[EMAIL]

DATED: this the ___ day of ____, 20__.

[ATTORNEY NAME] (MSB #______)
[LAW FIRM NAME]
[ADDRESS]
[PHONE]
[EMAIL]

VII. VERIFICATION (to be completed by the answering party)
STATE OF MISSISSIPPI )
) ss.
COUNTY OF ____ )

I, [DEFENDANT NAME], being first duly sworn, do hereby state that I have read the foregoing Answers to Plaintiff’s First Set of Interrogatories and that said Answers are true and correct to the best of my knowledge, information, and belief.

[DEFENDANT NAME]

SUBSCRIBED AND SWORN TO before me, the undersigned authority, on this the ___ day of _, 20.

NOTARY PUBLIC
My Commission Expires: ____

[// GUIDANCE: Mississippi requires that interrogatory answers be signed under oath by the responding party (MRCP 33(b)(1)). The attorney must also sign pursuant to MRCP 26(g). Adapt the verification block if the responding party is an entity; the signer should be an officer or authorized representative.]