IN THE DISTRICT COURT OF [COUNTY] COUNTY, NEBRASKA
[PLAINTIFF FULL NAME],
Plaintiff,
v.
[DEFENDANT FULL NAME],
Defendant.
Case No. [CASE NO.]
PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT [DEFENDANT NAME]
[// GUIDANCE: Insert party designations (e.g., “Plaintiff” / “Defendant”) consistent with the caption above and throughout the document.]
TABLE OF CONTENTS
- Applicability & Governing Authority
- Preliminary Statement
- Definitions
- General Instructions
- Specific Interrogatories (Nos. 1-[##])
- Verification
- Certificate of Service
1. APPLICABILITY & GOVERNING AUTHORITY
These Interrogatories are propounded pursuant to Nebraska Court Rules of Discovery in Civil Cases, Neb. Ct. R. Disc. §§ 6-326 to 6-343, and in particular Neb. Ct. R. Disc. § 6-337 (Interrogatories to Parties).
2. PRELIMINARY STATEMENT
Plaintiff [PLAINTIFF NAME] hereby serves the following Interrogatories upon Defendant [DEFENDANT NAME]. Pursuant to Neb. Ct. R. Disc. § 6-337(a), Defendant must serve sworn answers and any objections within thirty (30) days after service hereof, unless the Court orders otherwise or the parties stipulate to a different timeframe. Each answer must be preceded by the fully stated Interrogatory to which it responds.
3. DEFINITIONS
For purposes of these Interrogatories, the following terms have the meanings set forth below. All words herein shall be construed to include the plural or singular and the masculine, feminine, or neuter genders as the context requires.
- “Action” means the above-captioned lawsuit.
- “Communication” means any oral, written, electronic, or other transfer of information, including without limitation letters, emails, memoranda, text messages, and social-media postings.
- “Document” has the broadest meaning permitted under Neb. Ct. R. Disc. § 6-334 and includes electronically stored information (“ESI”).
- “Identify” or “Identity” when referring to a person means to state the person’s full name, present or last-known business and residential addresses, telephone number, and relationship to the parties. When referring to a document, it means to state the title, date, author, recipient, type of document, and present custodian.
- “Person” means any natural person, corporation, partnership, association, governmental entity, or other legal or business entity.
- “You” or “Your” refers to Defendant [DEFENDANT NAME], including all present and former agents, employees, officers, directors, representatives, and anyone acting or purporting to act on Defendant’s behalf.
[// GUIDANCE: Add or delete defined terms to align with case-specific issues.]
4. GENERAL INSTRUCTIONS
A. Counting of Interrogatories
1. The total number of discrete Interrogatories herein, including subparts, does not exceed fifty (50), the limit set by Neb. Ct. R. Disc. § 6-337(a).
2. If You believe any Interrogatory or subpart causes the numerical limit to be exceeded, answer the first fifty and specifically identify the Interrogatory(ies) You decline to answer on that basis.
B. Manner of Response
1. Each answer shall be made separately and fully, in writing and under oath, signed by the person making the answer.
2. Answers must be served on counsel for Plaintiff at the address indicated in the Certificate of Service.
C. Objections
1. State each objection with specificity and the grounds therefor.
2. If an objection pertains only to part of an Interrogatory, answer the unobjectionable portion.
D. Privilege & Work-Product
1. If any information is withheld on a claim of privilege or work-product protection, provide a privilege log that complies with Neb. Ct. R. Disc. § 6-326(b)(5), identifying the nature of the materials withheld, their date, author, recipients, and a general description sufficient to enable Plaintiff to assess the claim.
E. Duty to Supplement
You are under a continuing duty to seasonably supplement or correct your answers as required by Neb. Ct. R. Disc. § 6-337(d).
F. Time Period
Unless otherwise indicated, each Interrogatory seeks information from the inception of the relevant events through the present.
5. SPECIFIC INTERROGATORIES
[// GUIDANCE: Replace sample text with substantive, case-specific Interrogatories. Ensure numbering is continuous and remains within the 50-question cap.]
Interrogatory No. 1:
State Your full legal name, all other names You have used, Your present residential address, date of birth, and the last four digits of Your Social Security number.
Interrogatory No. 2:
Identify every Person who assisted, reviewed, or supplied information used in answering these Interrogatories.
Interrogatory No. 3:
Describe in detail Your version of the events giving rise to this Action, including the date, time, location, participants, and sequence of relevant acts or omissions.
Interrogatory No. 4:
Identify all Documents and Communications that support, refute, or otherwise relate to Your answer to Interrogatory No. 3.
Interrogatory No. 5:
State the factual basis for each affirmative defense pled in Your Answer, and Identify all Documents and Persons that support each such defense.
Interrogatory No. 6:
Identify every Person You expect to call as a witness at trial, specifying for each such Person the subject matter of his or her expected testimony.
Interrogatory No. 7:
Itemize and explain in detail each category of damages You claim in this Action, including the method of calculation and the Documents supporting each element.
Interrogatory No. 8:
Identify all insurance agreements under which any Person carrying on an insurance business may be liable to satisfy part or all of a possible judgment in this Action or to indemnify or reimburse for payments made to satisfy any such judgment.
Interrogatory No. 9:
Identify all prior or pending lawsuits, administrative actions, or arbitration proceedings in which You have been a party within the past ten (10) years, including the court or tribunal, caption, case number, nature of the claims, and outcome.
Interrogatory No. 10:
State whether You have destroyed, discarded, or otherwise disposed of any Documents or ESI relating to the matters alleged in the Complaint, and if so, describe the Documents or ESI, the date of destruction, and the reasons therefor.
[// GUIDANCE: Continue numbering (Interrogatory No. 11, etc.) up to, but not exceeding, 50 discrete Interrogatories including all subparts.]
6. VERIFICATION
I, ________, declare under penalty of perjury that I am duly authorized to make this Verification for and on behalf of Defendant [DEFENDANT NAME]; that I have read the foregoing answers to Interrogatories and know the contents thereof; and that the same are true and correct to the best of my knowledge, information, and belief.
Date: ____, 20__
[NAME & TITLE]
For Defendant [DEFENDANT NAME]
7. CERTIFICATE OF SERVICE
I hereby certify that on the _ day of __, 20__, a true and correct copy of the foregoing Plaintiff’s First Set of Interrogatories to Defendant [DEFENDANT NAME] was served upon all counsel of record by:
[ ] United States Mail
[ ] Hand Delivery
[ ] Email (by agreement)
[ ] Other: _____
to:
[OPPOSING COUNSEL NAME]
[LAW FIRM NAME]
[ADDRESS]
[EMAIL]
[PLAINTIFF’S COUNSEL NAME]
[LAW FIRM NAME]
[ADDRESS]
[PHONE]
[EMAIL]
[// GUIDANCE:
1. Adjust the Certificate of Service to match the method(s) of service authorized or agreed upon in your case.
2. Confirm whether notarization is required for the Verification under local practice. Nebraska generally permits unsworn verifications under penalty of perjury pursuant to Neb. Rev. Stat. § 25-1244, but local rules or the presiding judge may require notarization.
3. For corporate parties, ensure the individual signing the Verification has actual authority to do so (e.g., officer or managing agent).
4. Consider adding interrogatory subparts to elicit granular information, but track the cumulative “50-question” cap set by Neb. Ct. R. Disc. § 6-337(a).
5. Keep privilege logs contemporaneously—courts disfavor retroactive logging.
6. Maintain ESI preservation notices to avoid spoliation claims.]
Prepared for use by Nebraska litigation counsel. Customize carefully before service.