New Hampshire State Court Discovery Interrogatories

New Hampshire Litigation & Court Documents Updated October 6, 2026 Free Word and PDF

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THESE INTERROGATORIES ARE PROPOUNDED IN ACCORDANCE WITH RULE 23 OF THE RULES OF THE SUPERIOR COURT OF THE STATE OF NEW HAMPSHIRE APPLICABLE IN CIVIL ACTIONS. YOU MUST ANSWER EACH QUESTION SEPARATELY AND FULLY IN WRITING AND UNDER OATH. YOU MUST RETURN THE ORIGINAL AND ONE COPY OF YOUR ANSWERS WITHIN THIRTY (30) DAYS OF THE DATE YOU RECEIVED THEM TO THE PARTY OR COUNSEL WHO SERVED THEM UPON YOU. IF YOU OBJECT TO ANY QUESTION, YOU MUST NOTE YOUR OBJECTION AND STATE THE REASON THEREFORE. IF YOU FAIL TO RETURN YOUR ANSWERS WITHIN THIRTY (30) DAYS, THE PARTY WHO SERVED THEM UPON YOU MAY INFORM THE COURT, AND THE COURT SHALL MAKE SUCH ORDERS AS JUSTICE REQUIRES, INCLUDING THE ENTRY OF A CONDITIONAL DEFAULT AGAINST YOU.

STATE OF NEW HAMPSHIRE

[________________________________] SUPERIOR COURT

Docket No.: [________________________________]

Party	Role
[PLAINTIFF NAME],	Plaintiff
v.
[DEFENDANT NAME],	Defendant

PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT

ATTORNEY INFORMATION

Propounding Attorney:

Field	Information
Attorney Name	[________________________________]
NH Bar ID No.	[________________________________]
Firm Name	[________________________________]
Street Address	[________________________________]
City, State, ZIP	[________________________________]
Telephone	[________________________________]
Email	[________________________________]

Date of Service: [__/__/____]

I. INTRODUCTORY STATEMENT

Pursuant to New Hampshire Superior Court Rules ("N.H. Super. Ct. R.") 21 and 23, Plaintiff [________________________________] hereby propounds the following Interrogatories upon Defendant [________________________________], to be answered fully, separately, in writing, and under oath.

Response Deadline

Under Rule 23(i), answers are due 30 days after service, unless the parties extend the time by written agreement. Record the service date [DATE], any written extension or court order [DETAILS], and the calculated response date [DATE].

Interrogatory Limit

Rule 23(b) limits the total to 25 interrogatories, unless the court orders more for good cause after the proposed additional interrogatories are filed. Each subsidiary, incidental, or grouped question counts separately. This form contains 12 single questions; tailor them without adding hidden subquestions, and count any additional questions served in other sets. Final count across sets: [____]. Court order allowing additional requests, if any: [DATE / DOCKET ENTRY].

Under Rule 23(e), furnish the answering party an original and two copies with space after each question for an answer. If the parties agree to electronic transmission, use the agreed editable format and keep each answer immediately after its question under Rule 23(g).

Supplementation control. Apply Rule 21(g)'s specified duties to supplement or amend, together with any court order or party agreement: [DETAILS].

II. DEFINITIONS

For purposes of these Interrogatories, the following terms shall have the meanings set forth below:

1. "You," "Your," or "Defendant" means [DEFENDANT NAME]. For an entity, include information available to the party through the officer or agent answering under Rule 23(f).

2. "Plaintiff" means [________________________________], including its agents, representatives, and attorneys.

3. "Document" or "Documents" means any recorded information, whether paper, electronic, or other tangible form, within the scope of N.H. Super. Ct. R. 21, including electronically stored information ("ESI"), writings, drawings, graphs, charts, photographs, sound recordings, images, metadata, and other data or data compilations stored in any medium from which information can be obtained. This includes drafts and non-identical copies.

4. "Communication" means any transmission or exchange of information by any means, whether oral, written, or electronic, including but not limited to letters, memoranda, emails, text messages, instant messages, voicemails, social media messages, telephone conversations, and in-person discussions.

5. "Identify" means to provide a person's or entity's name, or a document's or record's title or a short description if untitled. A request for additional details should be a separately counted interrogatory under Rule 23(b).

6. "Incident" means the events, acts, omissions, and circumstances giving rise to this action, as described in the Complaint.

7. "Relevant Period" means the time period from [__/__/____] through the present, unless otherwise specified in an individual Interrogatory.

8. "Person" means any natural person, corporation, limited liability company, partnership, association, governmental body, or any other legal entity.

9. "Injury" includes economic, reputational, physical, emotional, or other harm alleged in the pleadings.

10. "Concerning" or "Relating to" means referring to or describing the specified issue.

III. INSTRUCTIONS

1. Answer each Interrogatory separately and fully, in writing and under oath, pursuant to N.H. Super. Ct. R. 23(f)–(g). Place each answer immediately after its question.

2. If any Interrogatory is objected to in whole or in part, state with specificity the grounds for each objection and respond to the Interrogatory to the extent it is not objectionable.

3. If You withhold otherwise discoverable information based on privilege, promptly and expressly identify the claim and describe the material's general character with enough detail for the other party to assess it, without revealing privileged content. N.H. Super. Ct. R. 21(c).

4. Apply the Relevant Period stated in each question. Do not treat a question as reaching unrelated claims or defenses.

5. Preserve potentially relevant ESI as required by Rule 25(b), and identify any preservation dispute for a prompt conference under Rule 25(a).

IV. INTERROGATORIES

Interrogatory No. 1: Identify the person who supplied the information used to prepare these answers.