State Court Discovery - Interrogatories - Oklahoma

[COURT HEADER]

IN THE DISTRICT COURT OF [___] COUNTY
STATE OF OKLAHOMA

[PLAINTIFF NAME],
  Plaintiff,

v.                          
[DEFENDANT NAME],
  Defendant.

Case No. [___]

___________________________________________
PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT ☐
___________________________________________

I. PRELIMINARY STATEMENT

Pursuant to Okla. Stat. tit. 12, § 3233 and Rule 26 of the Oklahoma Pleading Code, Plaintiff propounds the following Interrogatories, to be answered fully and separately, in writing and under oath, within the time prescribed by law.

II. DEFINITIONS

For purposes of these Interrogatories, the following terms have the meanings set forth below. Each definition should be construed in the broadest sense permissible under Oklahoma discovery rules.

1. “You” or “Your” means Defendant ☐, any present or former parent, subsidiary, affiliate, division, department, predecessor, successor, officer, director, agent, employee, representative, attorney, or any other person acting or purporting to act on Defendant’s behalf.

2. “Document” and “Electronically Stored Information” or “ESI” have the full breadth of meaning accorded by Okla. Stat. tit. 12, § 3226(A)(4), and include drafts and copies with notations.

3. “Communication” means any transmission of information, in any form, including oral statements, correspondence, email, text message, social-media post or message, voicemail, memorandum, or meeting minutes.

4. “Identify” or “Identity” when used with respect to:
   a. A natural person: give the person’s full name, present or last-known address, telephone number, and relationship to the parties.
   b. A business entity: give the entity’s full legal name, form, address of principal place of business, and the officer or agent most knowledgeable about the subject matter.
   c. A document or ESI: state its title, date, author(s), recipient(s), type, and Bates number or other location information.

5. “Incident” means the events alleged in Plaintiff’s Petition dated ☐.

6. The singular includes the plural and vice-versa; masculine, feminine, and neuter pronouns include all genders.

III. INSTRUCTIONS

A. Answer each Interrogatory separately and fully, in writing and under oath, pursuant to Okla. Stat. tit. 12, § 3233.

B. If You object to any Interrogatory or portion thereof, state the specific ground(s) and respond to all non-objected-to portions.

C. If any information requested is withheld on grounds of privilege, immunity, or work-product protection:

1. State the nature of the privilege asserted; and
2. Provide a privilege log identifying the withheld information in sufficient detail to allow the Court to rule on the claim, consistent with Okla. Stat. tit. 12, § 3226(B)(6).

Supplementation control. Apply only the duty supplied by the current governing rule, order, or agreement: [CITATION / TERMS / NONE IDENTIFIED]. Do not label these interrogatories “continuing” or demand supplementation beyond that authority.

E. The total number of Interrogatories, including discrete subparts, does not exceed the limit imposed by Okla. Stat. tit. 12, § 3233(B) absent leave of Court.

IV. INTERROGATORIES

1. Identify every person known to You who witnessed, or claims to have witnessed, any part of the Incident, and for each such person state the substance of the facts to which the witness is expected to testify.

2. Describe in detail the sequence of events that occurred on [date/time of Incident], including the actions of each individual employee, agent, or representative of Defendant involved in the Incident.

3. State the full name, job title, and contact information of every employee, agent, or representative of Defendant present at the location of the Incident at any time on [relevant date].

4. Identify all Documents or Communications, including photographs, video, or audio recordings, that relate to the Incident, and for each state its present custodian and location.

5. State the factual basis for each affirmative defense pleaded in Your Answer, identifying all supporting Documents and witnesses.

6. Describe all policies, procedures, guidelines, or training materials in effect on [relevant date] that governed or related to the conduct alleged in the Petition.

7. State all repairs, modifications, or alterations made to the [instrumentality/property] involved in the Incident during the twelve (12) months preceding and six (6) months following the Incident.

8. Identify every insurer that has or may have a duty to defend or indemnify You for the claims asserted, stating policy numbers, coverage limits, and reservation-of-rights status.

9. Itemize and describe all damages that You contend were caused by any person other than Defendant, including the amount of each category and the factual basis for such contention.

10. State the name, address, and specialty of each expert retained or specially employed to provide testimony in this action, and for each, provide (a) the subject matter of anticipated testimony, (b) the substance of facts and opinions, and (c) a summary of grounds for each opinion.

V. RESERVATION OF RIGHTS

Plaintiff reserves the right to serve additional interrogatories upon stipulation of the parties or with leave of Court as permitted by Okla. Stat. tit. 12, § 3233(B).

VI. 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 ☐ was served by:
[ ] Hand delivery
[ ] U.S. Mail, postage prepaid
[ ] E-mail (by agreement)
[ ] Other: _______________________________

to:

[Opposing Counsel Name]
[Firm]
[Address]
[Email]

_________________________________
[Attorney Name], OBA # [___]
[Law Firm]
[Address]
[Phone] | [Email]
ATTORNEY FOR PLAINTIFF

RESPONSE VERIFICATION CONTROL

The propounding paper does not prescribe a verification method. Before answers are served, enter the current rule or order, authorized signer, oath or declaration text, and any jurat requirement: [DETAILS]. Delete unused oath, declaration, and notary options.

END OF DOCUMENT