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STATE OF NORTH CAROLINA
IN THE GENERAL COURT OF JUSTICE
[☐ Superior Division / ☐ District Division]
[____] COUNTY
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[PLAINTIFF NAME], )
Plaintiff, )
)
v. ) File No. [______]
)
[DEFENDANT NAME], )
Defendant. )
)
PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT
(N.C. R. CIV. P. 26 & 33; LOCAL RULES COMPLIANCE)
[// GUIDANCE: Replace bracketed placeholders and check local rules for any county-specific discovery provisions, page-limit requirements, or mandated formatting (e.g., font size, margins).]
I. RECITALS & DISCOVERY CONTEXT
- Pursuant to Rules 26 and 33 of the North Carolina Rules of Civil Procedure (“NCRCP”) and any applicable Local Rules of the [____] County General Court of Justice, Plaintiff propounds the following Interrogatories to Defendant.
- These Interrogatories are intended to elicit information relevant to the claims and defenses in the above-captioned action and are within the numerical limit of fifty (50) interrogatories, inclusive of all discrete subparts, established by NCRCP 33(a).
- Unless otherwise agreed by the parties or ordered by the Court, Defendant must serve verified answers and any objections within thirty (30) days after service of these Interrogatories, except that a Defendant who has not yet answered the Complaint may serve answers within forty-five (45) days after service of the Summons and Complaint. N.C. R. Civ. P. 33(a).
II. DEFINITIONS
For purposes of these Interrogatories, the following definitions apply and shall be construed in the broadest sense consistent with the North Carolina Rules of Civil Procedure:
A. “Action” means the above-captioned lawsuit, including all pleadings, motions, orders, and discovery.
B. “Communication” means any transmission of information by any means, including oral, electronic, or written statements, emails, text messages, voicemails, social-media posts, or any other form.
C. “Document(s)” has the meaning set forth in NCRCP 34(a) and includes electronically stored information (“ESI”).
D. “Identify” (with respect to a natural person) means to state the person’s full name, present or last-known address, telephone number, and employer and position at the time relevant to the Interrogatory.
E. “Identify” (with respect to a non-natural person) means to state the entity’s full legal name, type of entity, address of principal place of business, and the identity of an individual knowledgeable about the matter addressed.
F. “Incident” refers to the events described in the Complaint occurring on or about [DATE], at or near [LOCATION].
G. “Plaintiff,” “Defendant,” “You,” and “Your” include the party’s officers, directors, employees, agents, representatives, attorneys, and all other persons acting or purporting to act on the party’s behalf.
[// GUIDANCE: Expand, modify, or narrow definitions to fit case-specific terminology (e.g., “Product,” “Policy,” “Accident”).]
III. GENERAL INSTRUCTIONS
- Duty to Supplement: These Interrogatories are continuing in nature. If at any time new or additional responsive information becomes known, Defendant must seasonably supplement its responses in accordance with N.C. R. Civ. P. 26(e).
- Answer Fully & Separately: Each Interrogatory must be answered separately and fully in writing under oath, citing the Interrogatory number. Boilerplate or generalized objections without specific factual bases are disfavored.
- Privilege & Work Product: If any information responsive to an Interrogatory is withheld under a claim of attorney-client privilege, work-product doctrine, or other protection, Defendant shall:
a. State the privilege invoked; and
b. Provide a privilege log that complies with N.C. R. Civ. P. 26(b)(5), identifying the nature of the information withheld, sufficient to enable Plaintiff and the Court to assess the applicability of the privilege. - Computation of Time: Time periods are calculated pursuant to N.C. R. Civ. P. 6(a). When service is made by mail, three (3) additional days are added under NCRCP 6(e).
- Scope & Relevance: Unless otherwise limited, each Interrogatory seeks information from the period beginning three (3) years before the Incident through the present.
- Meet-and-Confer: Consistent with NCRCP 26(f) and local practice, counsel shall confer in good faith to resolve any discovery dispute before seeking Court intervention.
IV. INTERROGATORIES
[// GUIDANCE: Below is a balanced set of “core” interrogatories suitable for most civil matters. Add, delete, or tailor to case needs while remaining within the 50-question limit.]
-
Identify all persons who assisted in preparing the answers to these Interrogatories, stating each person’s role and the specific Interrogatories for which they provided information.
-
State in detail the factual basis for each affirmative defense pleaded in Your Answer, including identification of all Documents and Communications supporting each defense.
-
Describe in chronological order Your version of how the Incident occurred, identifying all eyewitnesses and Documents that support Your description.
-
Identify each person whom You expect to call as an expert witness at trial and provide:
a. The subject matter on which the expert is expected to testify;
b. The expert’s opinions and the bases therefor;
c. The expert’s qualifications; and
d. All Documents reviewed or relied upon by the expert. -
Identify every non-expert witness You may call at trial and state the substance of the testimony You expect each witness to provide.
-
State the total amount of damages You claim to have sustained as a result of the Incident and provide a breakdown by category (e.g., property damage, lost profits, medical expenses, lost wages), including the method of computation and all supporting Documents.
-
Identify all insurance agreements under which any person carrying on an insurance business may be liable to satisfy all or part of a judgment in this Action or to indemnify or reimburse for payments made to satisfy the judgment. (See NCRCP 26(b)(2).)
-
For each communication between You and Plaintiff (or Plaintiff’s agents) concerning the Incident, identify the date, participants, medium, and content of the communication.
-
Describe all investigations conducted by or on Your behalf relating to the Incident, including the identity of the investigator(s), the date(s) of investigation, and a summary of findings.
-
Identify all photographs, videos, or other recordings relating to the Incident or any alleged damages, stating the date taken, the custodian, and a brief description of the content.
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If You contend that any third person is wholly or partially responsible for Plaintiff’s alleged damages, identify that person and state the factual and legal basis for Your contention.
-
Identify any prior claims, lawsuits, or administrative proceedings arising from substantially similar facts or occurrences in which You were involved within the past ten (10) years, stating the court/agency, case number, disposition, and nature of the claim.
-
Describe all safety policies, procedures, or protocols in effect at the time of the Incident that relate to the acts or omissions alleged in the Complaint, and identify each person responsible for enforcing such policies.
-
State whether You have been cited, fined, or otherwise penalized by any governmental agency concerning the Incident or related conduct and, if so, identify the agency, date, and outcome.
-
Identify all Documents You intend to introduce as exhibits at trial and state briefly the purpose for which each will be offered.
[// GUIDANCE: Renumber or expand the Interrogatories as necessary, remaining mindful of the 50-interrogatory cap.]
V. VERIFICATION
I, [NAME], being first duly sworn, say that I am the [TITLE/POSITION] for Defendant [DEFENDANT NAME]; that I have read the foregoing answers to Interrogatories and know the contents thereof; and that the same are true to my knowledge, except as to those matters stated upon information and belief, and as to those, I believe them to be true.
Date: _, 20
[Signature of Individual Respondent]
[Printed Name and Title]
Sworn to and subscribed before me this _ day of _, 20___.
Notary Public
My Commission Expires: _____
[// GUIDANCE: Multiple verifications may be required if more than one person/entity responds.]
VI. CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing Plaintiff’s First Set of Interrogatories to Defendant was served upon counsel for Defendant by [☐ hand delivery / ☐ U.S. Mail / ☐ email / ☐ NC e-Filing] addressed as follows:
[Name & Address of Opposing Counsel]
This the ___ day of _, 20.
[Attorney Name], N.C. Bar No. [_____]
[Law Firm Name]
[Address]
[Telephone] | [Email]
Counsel for Plaintiff
[END OF DOCUMENT]
[// GUIDANCE:
1. Retain proof of service (receipt, return email, or certificate).
2. For electronic service, ensure compliance with NCRCP 5(b) and any local e-filing pilot program rules.
3. Consider contemporaneous requests for production or requests for admission to streamline discovery.]