State Court Discovery - Interrogatories - Nebraska
Plaintiff's First Set of Interrogatories to Defendant
Before service: Confirm the party, claims, disputed events, and any discovery order. Neb. Ct. R. Disc. § 6-333(a)(1) permits up to fifty interrogatories including discrete subparts unless the parties stipulate or the court orders otherwise. Count prior interrogatories served on this party. Tailor the questions below to the claims and remove any that do not fit.
IN THE DISTRICT COURT OF [COUNTY] COUNTY, NEBRASKA
Case No.: [________________]
| Party | Role |
|---|---|
| [PLAINTIFF NAME], | Plaintiff |
| v. | |
| [DEFENDANT NAME], | Defendant |
Plaintiff's First Set of Interrogatories to Defendant [Name]
Plaintiff [FULL NAME] serves the following interrogatories on Defendant [FULL NAME] under Neb. Ct. R. Disc. § 6-333. The disputed event or transaction is [SPECIFY DATE, LOCATION, AND SUBJECT: ________________________________]. The relevant complaint claims and answer defenses are [IDENTIFY PARAGRAPHS OR COUNTS: ________________________________].
Service and count record: This set contains [____] interrogatories counting discrete subparts. Plaintiff previously served [____] interrogatories on this Defendant. The total after this set is [____]. [STIPULATION OR COURT ORDER ALTERING LIMIT, IF ANY: ________________________________].
Instructions for answers and objections
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Answer each interrogatory separately and fully in writing under oath to the extent it is not objected to. The person making the answers signs them; an attorney who objects signs the objections. Reproduce each interrogatory before the answer or objection. Neb. Ct. R. Disc. § 6-333(b)(3)-(6).
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An objection must state its grounds and specifically explain why the interrogatory is objectionable on those grounds. An otherwise discoverable item withheld on privilege or work-product grounds must be identified as § 6-326(b)(4) requires, without revealing the protected content.
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The ordinary response period is thirty days after service of these interrogatories. A defending party may use the longer of forty-five days after service of the summons or thirty days after interrogatory service. A court order or stipulation may change that period. Neb. Ct. R. Disc. § 6-333(b)(2). Service date: [__/__/____]. Applicable order or stipulation: [NONE / DETAILS].
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Under § 6-326(e), supplement or correct a materially incomplete or incorrect response in a timely manner when the corrective information has not otherwise been made known during discovery or in writing, or when ordered by the court.
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On demand, Plaintiff will supply an electronic copy of these interrogatories in a readily editable format under § 6-333(a)(3).
Interrogatories
Interrogatory No. 1. Identify the people with firsthand knowledge of [SPECIFIC EVENT OR DISPUTED FACT], stating for each the person's name, role, and the subject of that knowledge. [REMOVE ANY UNNECESSARY PERSONAL CONTACT DATA REQUEST.]
Interrogatory No. 2. Describe the actions Defendant took concerning [SPECIFIC EVENT OR CONTRACTUAL DUTY] on [DATE OR LIMITED PERIOD], including the sequence of material acts and the people who took them.
Interrogatory No. 3. State the factual basis for Defendant's denial of paragraph(s) [____] of the Complaint concerning [SPECIFIC ISSUE], identifying the documents or other records on which Defendant relies by title or description and date.
Interrogatory No. 4. For affirmative defense [IDENTIFY DEFENSE AND ANSWER PARAGRAPH], state the facts on which Defendant relies and identify the witnesses or records supporting those facts.
Interrogatory No. 5. Identify any insurance agreement under which an insurance business may be liable to satisfy all or part of a possible judgment on [IDENTIFIED CLAIM], or to indemnify or reimburse a payment on that judgment. [REMOVE IF INSURANCE IS IRRELEVANT; SEE § 6-326(b)(2).]
Additional interrogatory, if needed and within the limit: [NUMBER AND SINGLE TAILORED QUESTION LINKED TO A CLAIM OR DEFENSE].
Dated: [__/__/____]
Serving attorney or party signature: [________________________________]
Printed name and Nebraska bar number, if attorney: [________________________________]
Address: [________________________________]
Email and telephone: [________________________________]
Certificate of Service
I certify that on [__/__/____], I served this set of interrogatories on [OPPOSING COUNSEL OR UNREPRESENTED PARTY] by [ACTUAL PERMITTED METHOD] at [ADDRESS OR ELECTRONIC DESTINATION].
Signature: [________________________________]
Under Neb. Ct. R. Disc. § 6-326(f) and Neb. Ct. R. Pldg. § 6-1105(d)(2), discovery interrogatories and their service certificate ordinarily are served without filing unless relevant to a motion or the court orders filing.
Sources and References
About this template
- Last updated
- October 6, 2026
- Citations checked
- October 6, 2026
- Jurisdiction
- Nebraska
- Category
- Litigation & Court Documents
Legal authority
- Neb. Ct. R. Disc. § 6-326 (scope, privilege, supplementation)
- Neb. Ct. R. Disc. § 6-333 (interrogatories to parties)
- Neb. Ct. R. Pldg. § 6-1105 (service and filing of discovery documents)
These are the filings that drive a lawsuit through the system: complaints, answers, motions, briefs, discovery requests and responses, and post-judgment papers. Each has its own format requirements under federal and state procedural rules, and each has a deadline that cannot be missed without consequences. Clean, procedurally correct filings move a case forward; sloppy ones invite motions to strike, amended responses, and avoidable delays.
Not legal advice
This template is provided for informational purposes. We recommend having an attorney review any legal document before signing, especially for high-value or complex matters.
Checked against the law it cites
A reviewer verified this template's legal citations against the official source on October 6, 2026.
Neb. Ct. R. Disc. § 6-326(b)(1) (checked October 6, 2026): "Parties may obtain discovery regarding any nonprivileged matter that is relevant to the subject matter involved in the pending action, whether it relates to the claim or defense of the party seeking discovery or to the claim or defense of any other party."
Neb. Ct. R. Disc. § 6-326(b)(2) (checked October 6, 2026): "A party may obtain discovery of the existence and contents of any insurance agreement under which an insurance business may be liable to satisfy all or part of a possible judgment in the action or to indemnify or reimburse for payments made to satisfy the judgment."
Neb. Ct. R. Disc. § 6-326(b)(4) (checked October 6, 2026): "When a party withholds information otherwise discoverable by claiming that the information is privileged or subject to protection as work product, the party must: (A) expressly make the claim; and (B) describe the nature of the documents, communications, or tangible things not produced or disclosed"
Neb. Ct. R. Disc. § 6-326(e)(1) (checked October 6, 2026): "A party who has made a disclosure under Rule 26(c) – or who has responded to an interrogatory, request for production, or request for admission – must supplement or correct its disclosure or response"
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