STATE OF NEW HAMPSHIRE
[__] SUPERIOR COURT
Docket No. [______]
[PLAINTIFF NAME],
Plaintiff,
v.
[DEFENDANT NAME],
Defendant.
PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT [DEFENDANT NAME]
I. DOCUMENT HEADER
- Effective Date of Service: [DATE]
- Governing Procedural Law: New Hampshire Superior Court Civil Rules (“N.H. Super. Ct. R.”), including without limitation Rules 26 and 33.
- Addressee: Defendant [DEFENDANT NAME] (“Defendant,” “You,” or “Your”).
- Propounding Party: Plaintiff [PLAINTIFF NAME] (“Plaintiff”).
[// GUIDANCE: Insert court, docket, and party information exactly as it appears on the complaint caption.]
II. DEFINITIONS
For purposes of these Interrogatories:
“Document” means any recorded information—paper, electronic, or other tangible form—within the scope of N.H. Super. Ct. R. 26, including metadata.
“Communication” means any oral, written, or electronic transmission of information, including emails, text messages, social-media messages, voicemails, or in-person statements.
“Identify” or “state the identity of” when referring to a natural person requires You to provide: (a) full name; (b) present or last-known address; (c) present or last-known employer and position; and (d) telephone number or email address, if known.
“Injury” includes economic, reputational, physical, or emotional harm alleged in the pleadings.
Unless otherwise indicated, the terms “including” or “include” are illustrative, not exhaustive.
[// GUIDANCE: Add or delete definitions to fit the specific dispute.]
III. OPERATIVE PROVISIONS (GENERAL INSTRUCTIONS)
-
Number & Scope
a. This is Plaintiff’s First Set and consists of 25 interrogatories, inclusive of discrete subparts, in compliance with N.H. Super. Ct. R. 33(a)(1).
b. Each interrogatory is continuing; You must reasonably supplement answers under N.H. Super. Ct. R. 26(e). -
Response Deadline
a. Written answers, under oath, must be served within 30 days of service (or within 45 days if these Interrogatories accompany the Summons and Complaint), unless the parties stipulate or the Court orders otherwise. See N.H. Super. Ct. R. 33(a)(2). -
Manner of Answering
a. Restate each interrogatory before each answer.
b. If any interrogatory is objected to, state with specificity the grounds and respond to all unobjectionable portions.
c. When asserting any privilege, produce a privilege log that complies with N.H. Super. Ct. R. 26(b)(5)(A), identifying the nature of the document, subject matter, sender, recipients, and privilege claimed. -
Electronically Stored Information (“ESI”)
Describe the systems, custodians, and retention policies applicable to responsive ESI. -
Duty to Preserve
These Interrogatories serve as a formal reminder of Your common-law and rule-based preservation obligations.
[// GUIDANCE: Consider adding an ESI protocol or reference to an existing agreed-upon order if the matter is e-discovery intensive.]
IV. INTERROGATORIES
-
Identify all persons who prepared, reviewed, or assisted in preparing Your answers to these Interrogatories.
-
Describe in detail the factual bases for each affirmative defense pleaded in Your Answer, including all Documents and witnesses that support each defense.
-
State the name, address, and subject matter of knowledge of each person likely to have discoverable information that You may use to support Your claims or defenses.
-
For every communication between You and Plaintiff concerning the claims in this action, identify the date, participants, medium, and substance of each communication.
-
Identify all Documents that You contend support Your denial of liability in this action.
-
State the total amount of damages, costs, or expenses You contend were caused by Plaintiff, including the method of calculation.
-
Describe Your document retention policies in effect from [RELEVANT PERIOD] to present, including any changes made after litigation was anticipated.
-
Identify all insurance agreements under which any insurer may be liable to satisfy part or all of a judgment in this action.
-
Describe each instance, within the past five years, in which You have been a party to litigation involving similar claims, stating the court, docket number, nature of the claim, and final disposition.
-
Identify all expert witnesses You may call at trial and state the subject matter, opinions, and bases for those opinions.
-
State the date, time, and place of each meeting between You and any third party concerning the circumstances alleged in the Complaint.
-
Describe in detail any investigation You conducted regarding Plaintiff’s allegations, including the persons involved and Documents reviewed.
-
Identify all social-media accounts maintained by You that contain posts, messages, or media concerning the matters alleged.
-
State all facts supporting any contention that Plaintiff’s alleged injuries were caused in whole or in part by the acts or omissions of third parties.
-
Describe any settlement discussions, offers, or demands exchanged between the parties, including dates and participants.
-
Identify all Documents You intend to introduce as exhibits at trial.
-
State the precise time line of events on [SPECIFIC DATE OR INCIDENT], including each participant’s actions.
-
Identify all electronic devices (e.g., computers, smartphones, tablets) in Your possession or control that contain information relevant to the claims or defenses.
-
Describe all steps taken to locate and collect responsive ESI, including search terms used.
-
State the factual basis for any contention that Plaintiff failed to mitigate damages.
-
Identify any surveillance, recordings, or photographs relating to the incident(s) described in the Complaint.
-
Describe all safety protocols, guidelines, or policies applicable at the time of the incident and whether each was followed.
-
State whether You contend any statute of limitation or repose bars Plaintiff’s claims and describe the factual basis for that contention.
-
Identify each person whom You expect to call as a witness at trial and summarize the expected testimony.
-
Describe all steps taken to preserve evidence after You reasonably anticipated litigation.
[// GUIDANCE: Tailor, add, or delete interrogatories to match the specific causes of action and factual issues in dispute. Maintain the 25-interrogatory cap absent court order.]
V. VERIFICATION
(To be provided with Answers; included here for completeness.)
I, [NAME], being duly sworn, depose and state that I am duly authorized to make this verification for and on behalf of Defendant; 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.
[NAME], [TITLE]
On behalf of Defendant [DEFENDANT NAME]Date: _____
[// GUIDANCE: Remove Verification from propounding party’s draft if local practice requires only the responding party to verify.]
VI. CERTIFICATE OF SERVICE
I hereby certify that on [DATE] a copy of the foregoing Plaintiff’s First Set of Interrogatories to Defendant [DEFENDANT NAME] was served via:
☐ Electronic filing/notification system
☐ Email to counsel of record
☐ U.S. Mail, postage prepaid
☐ Hand delivery
to:
[OPPOSING COUNSEL NAME]
[FIRM NAME]
[ADDRESS]
[EMAIL]
[ATTORNEY NAME], Esquire
Counsel for Plaintiff [PLAINTIFF NAME]
Bar No. [__]
[FIRM NAME]
[ADDRESS]
[PHONE] | [EMAIL]
[// GUIDANCE:
1. Check local superior-court rules for any county-specific administrative orders that modify statewide discovery deadlines.
2. If the case is in Circuit Court-District Division, confirm that Rules 3.22 and 3.25 (District Division discovery rules) do not impose different limits.
3. Update privilege-log language if the parties stipulate to an alternative logging protocol.
4. Confirm that electronic service complies with N.H. Super. Ct. Admin. Order 1 and any applicable e-court rules.
]