[COURT NAME]
[COUNTY], NEVADA
[PLAINTIFF NAME],
Plaintiff,
v.
[DEFENDANT NAME],
Defendant.
Case No. [_]
Dept. No. [_]
[PROPONENT PARTY]’S FIRST SET OF INTERROGATORIES TO [RESPONDING PARTY]
Date: [MM/DD/YYYY]
TABLE OF CONTENTS
- Preliminary Statement and Authority
- Definitions
- General Instructions
- General Objections
- Interrogatories
- Verification (for Responding Party)
- Certificate of Service
1. PRELIMINARY STATEMENT AND AUTHORITY
Pursuant to Nevada Rule of Civil Procedure (“NRCP”) 33 and all other applicable rules, [PROPONENT PARTY] propounds the following Interrogatories to [RESPONDING PARTY] to be answered fully, in writing, and under oath within thirty (30) days after service hereof, except that a Defendant served with these Interrogatories together with the summons and complaint shall respond within forty-five (45) days. See Nev. R. Civ. P. 33(b)(2).
[// GUIDANCE: Do not exceed forty (40) interrogatories, including discrete subparts, absent stipulation or court order. Nev. R. Civ. P. 33(a)(1). Delete or renumber as needed.]
2. DEFINITIONS
For purposes of these Interrogatories, the following definitions apply:
- “You,” “Your,” or “Responding Party” means [RESPONDING PARTY], including all present and former agents, employees, officers, directors, partners, representatives, attorneys, insurers, and any other person acting or purporting to act on its behalf.
- “Document” and “Communication” have the broadest meaning permitted under NRCP 26 and 34, and include electronically stored information (“ESI”).
- “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. - “Incident” means the events alleged in the Complaint dated [DATE OF COMPLAINT].
- “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 all information reasonably available to You, including that in the possession of Your attorneys, investigators, or other agents.
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 any information under a claim of privilege or protection, expressly state the privilege claimed and provide a privilege log that complies with Nev. R. Civ. P. 26(b)(5)(A).
D. These Interrogatories are deemed continuing; if You obtain additional responsive information, You must serve supplemental answers promptly, and in any event no later than fourteen (14) days after discovery. See Nev. R. Civ. P. 26(e).
E. Unless otherwise specified, the relevant time period is [START DATE] through the present.
4. GENERAL OBJECTIONS
- Objection to each Interrogatory to the extent it seeks information protected by the attorney–client privilege, work-product doctrine, or any other applicable privilege.
- Objection to the extent any Interrogatory is vague, ambiguous, overbroad, unduly burdensome, or not reasonably calculated to lead to the discovery of admissible evidence.
- Objection to the extent an Interrogatory requests information beyond the scope allowed under the NRCP or exceeds the limitation of forty (40) Interrogatories including subparts.
[// GUIDANCE: Tailor or delete boilerplate objections to comply with current Nevada case law discouraging reflexive, non-specific objections.]
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
Identify all expert witnesses You expect to call at trial, stating each expert’s name, address, field of expertise, subject matter of expected testimony, and a summary of opinions to be expressed.
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 any felony or crime involving dishonesty in the past ten (10) years; if so, identify the offense, jurisdiction, and date of conviction.
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
State the name and contact information of every person with whom You have discussed this litigation, excluding counsel, and describe the substance of each discussion.
Interrogatory No. 19
Describe any surveillance conducted on [OPPOSING PARTY] or any agent thereof in connection with the Incident, including dates, locations, and identity of the surveilling individual or entity.
Interrogatory No. 20
Identify all facts and documents that support any claim for attorneys’ fees or costs You intend to seek in this action.
[// GUIDANCE: Add or remove interrogatories as needed, ensuring the total number of discrete subparts remains within NRCP 33(a)(1).]
6. VERIFICATION (TO BE COMPLETED BY RESPONDING PARTY)
I, [NAME], declare under penalty of perjury under the laws of the State of Nevada that I am the [TITLE/POSITION] of [RESPONDING PARTY]; that I have read the foregoing Answers to Interrogatories; and that the answers are true and correct to the best of my knowledge, information, and belief.
Date: ____
Signature: ______
Printed Name: _________
[// GUIDANCE: Verification must be served with the answers. Nev. R. Civ. P. 33(b)(3).]
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:
☐ Electronic service via [E-Service Provider] pursuant to NRCP 5(b);
☐ U.S. Mail, postage prepaid;
☐ Hand delivery;
☐ Other: ________.
to the following:
[OPPOSING COUNSEL NAME]
[LAW FIRM]
[ADDRESS]
[EMAIL]
Date: ____
Signature: ______
Name: [ATTORNEY NAME]
Nevada Bar No. [_____]
Attorney for [PROPONENT PARTY]
[// GUIDANCE: Review for compliance with local rules or departmental preferences, including formatting, margins, and citation style. Customize interrogatories to align with case strategy and factual allegations.]