State Court Discovery - Interrogatories - Nevada

[COURT NAME]

[COUNTY], NEVADA

[PROPONENT PARTY]’S FIRST SET OF INTERROGATORIES TO [RESPONDING PARTY]

Date: [MM/DD/YYYY]

TABLE OF CONTENTS

1. Preliminary Statement and Authority
2. Definitions
3. General Instructions
4. Response Requirements
5. Interrogatories
6. Verification (for Responding Party)
7. Certificate of Service

1. PRELIMINARY STATEMENT AND AUTHORITY

Pursuant to Nevada Rule of Civil Procedure (“NRCP”) 33, [PROPONENT PARTY] propounds the following Interrogatories to [RESPONDING PARTY]. Unless the parties stipulate to another period under NRCP 29 or the court orders otherwise, answers and objections must be served within thirty (30) days after service. See NRCP 33(b)(2).

2. DEFINITIONS

For purposes of these Interrogatories, the following definitions apply:

1. “You,” “Your,” or “Responding Party” means [RESPONDING PARTY]. For an entity, answers must be made by an officer or agent who furnishes the information available to the entity under NRCP 33(b)(1)(B).
2. “Document” and “ESI” mean documents and electronically stored information within NRCP 34(a)(1)(A), including writings, drawings, photographs, sound recordings, images, and other data stored in any medium from which information can be obtained. “Communication” means an oral, written, or electronic transmission of information.

3. “Identify” or “identity” when used with reference to:
   a. A person—state the full name, last known address and telephone number, and relationship to the parties.
   b. A document—state the date, author, recipient(s), type, and current custodian.

4. “Incident” means the events alleged in the Complaint dated [DATE OF COMPLAINT].

5. “Relate to,” “refer to,” or “concerning” mean directly or indirectly describing, evidencing, constituting, or pertaining to.

3. GENERAL INSTRUCTIONS

A. Answer each Interrogatory separately and fully in writing under oath, based on information available to the Responding Party. See NRCP 33(b)(1), (3).
B. If You object to any Interrogatory, state the specific legal and factual basis for each objection and respond to the extent the Interrogatory is not objectionable.
C. If You withhold otherwise discoverable information under a claim of privilege or trial-preparation protection, expressly make the claim and describe the nature of the withheld information sufficiently to permit assessment of the claim without revealing the protected information. See NRCP 26(b)(5)(A).
D. Timely supplement or correct an answer if You learn that it is materially incomplete or incorrect and the additional or corrective information has not otherwise been made known during discovery or in writing. See NRCP 26(e)(1).
E. Unless otherwise specified, the relevant time period is [START DATE] through the present.

4. RESPONSE REQUIREMENTS

1. Quote each Interrogatory in full immediately before its answer or objection. See NRCP 26(f).
2. State each objection with specificity. A ground not stated in a timely objection is waived unless the court excuses the failure for good cause. See NRCP 33(b)(4).
3. The person making the answers must sign them, and the attorney making objections must sign the objections. See NRCP 33(b)(5).
4. This set contains twenty (20) Interrogatories. Any additions must be counted against NRCP 33(a)(1)'s limit of forty (40) written Interrogatories, including all discrete subparts, unless the parties stipulate or the court orders otherwise.
5. Discovery must remain relevant to a party's claims or defenses and proportional to the needs of the case under NRCP 26(b)(1).

5. INTERROGATORIES

Interrogatory No. 1
Identify every person known to You who witnessed the Incident or has knowledge of any facts alleged in the pleadings, and state the substance of their knowledge.

Interrogatory No. 2
Describe in chronological detail Your version of how the Incident occurred, including the actions of each party involved.

Interrogatory No. 3
Identify all documents and ESI that support Your answer to Interrogatory No. 2.

Interrogatory No. 4
State the nature and amount of each category of damages You claim in this action and the method of calculation for each category.

Interrogatory No. 5
Identify all health-care providers who have treated You for injuries allegedly resulting from the Incident and specify the dates and nature of each treatment.

Interrogatory No. 6
Describe all prior injuries or medical conditions similar to those You allege herein, including dates, nature, and treatment received.

Interrogatory No. 7
If You contend that [OPPOSING PARTY] was negligent, specify each act or omission You contend constituted negligence and identify all evidence supporting that contention.

Interrogatory No. 8
If You contend that any third person was responsible in whole or in part for the Incident, identify the person and state the factual basis for Your contention.

Interrogatory No. 9
Identify all photographs, videos, diagrams, or other recordings of the Incident or its aftermath, stating the date created, creator, and present custodian.

Interrogatory No. 10
State whether You or anyone acting on Your behalf has given any recorded or written statement regarding the Incident, and for each such statement identify the date, person giving the statement, person taking the statement, and current location.

Interrogatory No. 11
Describe any repairs, alterations, or remedial measures made to the property or instrumentality involved in the Incident after it occurred, including dates and persons involved.

Interrogatory No. 12
Identify all insurance agreements under which any person carrying on an insurance business may be liable to satisfy part or all of a judgment in this action or to indemnify or reimburse for payments made to satisfy the judgment.

Interrogatory No. 13
State the full factual basis for each affirmative defense pled in Your Answer.

Interrogatory No. 14
Subject to the timing and protections of NRCP 16.1, 16.2, 16.205, and 26(b)(4), identify each expert witness whose opinions You expect to present at trial and state the subject matter of the expected testimony.

Interrogatory No. 15
Describe all training, policies, and procedures in effect at the time of the Incident that are relevant to the claims or defenses in this action.

Interrogatory No. 16
State whether You have been convicted of a crime punishable by death or imprisonment for more than one year for which the later of release from confinement or expiration of parole, probation, or sentence occurred within the past ten (10) years. If so, identify the offense, jurisdiction, conviction date, and the applicable release or expiration date. See Nev. Rev. Stat. § 50.095.

Interrogatory No. 17
Identify any social media accounts (including platform and username) You maintained during the relevant period and state whether any content relating to the Incident was posted, modified, or deleted.

Interrogatory No. 18
Identify each nonlawyer fact witness with whom You communicated about the Incident or the facts alleged in the pleadings, and state the general subject of each nonprivileged communication. Do not disclose attorney–client communications or protected trial-preparation material.

Interrogatory No. 19
Subject to NRCP 26(b)(3) and (b)(5), identify any nonprivileged surveillance of [OPPOSING PARTY] relating to the Incident, including the dates and locations of surveillance and the present custodian of any resulting recording.

Interrogatory No. 20
Identify all facts and documents that support any claim for attorneys’ fees or costs You intend to seek in this action.

6. VERIFICATION (TO BE COMPLETED BY RESPONDING PARTY)

I, [NAME], am the [TITLE/POSITION] of [RESPONDING PARTY] and have read the foregoing Answers to Interrogatories.

Execution location: ☐ Nevada ☐ Outside Nevada

If executed in Nevada: “I declare under penalty of perjury that the foregoing is true and correct.”

If executed outside Nevada: “I declare under penalty of perjury under the law of the State of Nevada that the foregoing is true and correct.”

See Nev. Rev. Stat. § 53.045.

Date: ______________________

Signature: ______________________________
Printed Name: ___________________________

7. CERTIFICATE OF SERVICE

I hereby certify that on the ___ day of __________, 20__, I served the foregoing [PROPONENT PARTY]’S FIRST SET OF INTERROGATORIES TO [RESPONDING PARTY] by:

☐ The court's electronic filing system under NRCP 5(b)(2)(E) and NEFCR 9;
☐ Other electronic means consented to in writing under NRCP 5(b)(2)(E): [________________];
☐ U.S. Mail to the recipient's last-known address under NRCP 5(b)(2)(C);
☐ Hand delivery under NRCP 5(b)(2)(A);
☐ Other method consented to in writing under NRCP 5(b)(2)(F): [________________].

to the following:

[OPPOSING COUNSEL NAME]
[LAW FIRM]
[ADDRESS]
[EMAIL]

Date: ______________________

Signature: ______________________________
Name: [ATTORNEY NAME]
Nevada Bar No. [___]
Attorney for [PROPONENT PARTY]

FILING NOTE

Under NRCP 5(d)(1), Interrogatories and their answers must not be filed until they are used in the proceeding or the court orders filing. Check the assigned court's local rules and electronic-filing requirements before service or filing.

SOURCES AND REFERENCES

• Nevada Rules of Civil Procedure — current official compilation
• Nevada Supreme Court — rule amendments for all Nevada courts
• Nev. Rev. Stat. Chapter 50 — § 50.095
• Nev. Rev. Stat. Chapter 53 — § 53.045